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ACA Information Reporting Deadlines for 2017 Tax Year

If you are an employer who provides minimum essential coverage to an individual during a calendar year, certain information must be reported to the IRS about the coverage provided. If your organization is an applicable large employer, information must be reported to the IRS information about the health care coverage, if any, that was offered to full-time employees. Below are the due dates you should put on your calendar. You will meet the IRS reporting requirements to file if the form is properly addressed and mailed on or before the due date.

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DEADLINE EXTENDED FOR SUPPLYING ACA FORMS TO EMPLOYEES

On December 22, 2017, the IRS issued Notice 2018-06 which extended by 30 days the 2018 due date for distributing 2017 health coverage information forms 1095-C or 1095-B to employees, regarding the health care coverage offered to them. The new deadline for supplying these forms to employees is March 2, 2018.

The due dates for filing 2017 information returns with the IRS have not changed. For 2018, the due dates to file information returns with the IRS remain Feb. 28 for paper filers or April 2 for electronic filers.

Notice 2018-6 also extended good-faith transition relief to 2017 information reporting. This relief applies only to incorrect and incomplete information reported on Form 1095-C or 1095-B, and not to a failure to timely furnish or file the forms.

Below are links to the final ACA information reporting forms and instructions on the IRS website:

Notable changes to the forms include:

  • Form 1094-C: A box in Line 22 called “Section 4980H Transition Relief” has been removed. It is not applicable in 2017.
  • Forms 1095-B and 1095-C: A paragraph called “Additional information” in the instructions for recipients directs individuals to an IRS webpage providing information on the individual and employer shared-responsibility provisions and premium tax credits.

FILING DEADLINES

Due DateDeadline
January 31, 2018 Deadline extended to March 2, 2018Supply Forms 1095-C to employees.
February 28, 2018File paper Forms 1095-C with transmittal Form 1094-C.
March 31, 2018e-File Forms 1095-C with transmittal Form 1094-C.

REPORTING BY APPLICABLE LARGE EMPLOYERS

Employers with 50 or more full-time employees, including full-time equivalent employees, use transmittal Form 1094-C and information return Form 1095-C to report the information required under the Affordable Care Act about offers of health coverage and enrollment in health coverage for their employees. In addition to reporting the coverage that they offer, applicable large employers who sponsor self-insured group health plans will use Forms 1094-C and 1095-C to report information about the coverage they provide to the covered individuals.

Small employers with fewer than 50 full-time employees are exempt from some of the reporting requirements, but not all. Small employers must provide the following:

  • Complete and file Forms 1094-B and 1095-B with the IRS.
  • Provide full-time employees with a copy of Form 1095-B.
  • File Forms 1094-C and 1095-C if they are members of a controlled or affiliated service group that collectively has at least 50 full-time employees.

For more information, see the IRS’s questions and answers about Information Reporting by Health Coverage Providers and Reporting of Offers of Health Insurance Coverage by Employers.

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