As reviewed in a previous article, the IRS designed Forms 1095 and 1094 to help measure compliance with provisions in the Affordable Care Act (ACA) and assess penalties for noncompliance.
The IRS originally intended for 2018 forms to be due as outlined in Sections 6055 and 6056 of the Internal Revenue Code. The due date was originally January 31, 2019, for insurers, self-insured employers, certain other coverage providers and applicable large employers to provide this information to individuals. However, following consultation with stakeholders, the IRS determined a substantial number of employers need additional time to gather and analyze information to prepare Forms 1095-B and 1095-C to be furnished to individuals. Therefore, the IRS released Notice 2018-94, which provides an automatic extension to March 4, 2019, for 2018 health coverage information-reporting Forms 1095-B and 1095-C to individuals. This extension also applies to the good-faith transition relief under §6721 and §6722. Because this 30-day extension is granted automatically, the IRS won’t respond to extension requests sent by entities prior to the release of the notice.
While the notice provides relief for the January 31 deadline, it doesn’t change the due dates for providing Forms 1094-B, 1095-B, 1094-C and 1095-C to the IRS. Those dates remain February 28, 2019, when paper filing and April 1, 2019, for electronic filers. Employers may request a 30-day extension for filing forms with the IRS by submitting Form 8809.
Employers or other coverage providers that don’t comply with these extended due dates remain subject to penalties for failure to furnish and file timely.
Effect on Individual Taxpayers
Due to the extension, individuals might not receive this form by the time they file their 2018 return. However, taxpayers may rely on other information received from their employer or other coverage provider for purposes of filing their returns, including determining eligibility for the premium tax credit and confirming they had minimum essential coverage. Taxpayers don’t need to amend their returns once they receive Form 1095-C, but they should keep the form with their tax records.
Due to a provision in the Tax Cuts and Jobs Act, the individual shared responsibility payment will be reduced to zero for months beginning after December 31, 2018. The U.S. Department of the Treasury and the IRS are studying how the reporting requirements should change, if at all, for future years.
For more information or assistance with preparing these forms, contact Brandon or your trusted BKD advisor.