2019 ACA Reporting Requirement Extended by IRS

Thoughtware Alert Dec 16, 2019
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Internal Revenue Code Sections 6055 and 6056 require 2019 Forms 1094 and 1095 to be furnished to individuals by January 31, 2020. Notice 2019-63 has provided an automatic extension of this due date to March 2, 2020. This notice also provides 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 prior to the notice’s release.

Notice 2019-63 doesn’t extend the time for filing the 2019 Forms 1094 and 1095 with the IRS. These forms must be submitted to the IRS on or before February 28, or March 31 if filed electronically. An automatic extension is available to employers and other coverage providers who submit Form 8809 on or before the due date.

Affordable Care Act (ACA) Information-Reporting Forms

Employers or other coverage providers who don’t comply with these extended due dates remain subject to penalties for failure to furnish and file timely.

Relief Regarding Furnishing Form 1095-B for 2019

A provision in the Tax Cuts and Jobs Act, enacted on December 22, 2017, reduced the individual shared responsibility payment to zero for months beginning after December 31, 2018. Due to this provision, an individual doesn’t need the information provided on Form 1095-B to file an income tax return.  

As previously stated in Notice 2018-94, the U.S. Department of the Treasury and the IRS were studying whether and how the reporting requirements would change in regard to this provision, if at all, in future years. They’re continuing to study this, but in the meantime, they’ve provided some relief. Reporting entities required to provide Form 1095-B to individuals must continue to do so; however, a penalty under §6722 won’t be assessed for failing to provide a Form 1095-B to responsible individuals if the following two conditions are met:

  1. The reporting entity posts a notice prominently on its website stating that responsible individuals may receive a copy of their 2019 Form 1095-B upon request, along with an email address and a physical address to which a request may be sent, as well as a telephone number that can be used to contact the reporting entity with any questions.
  2. The reporting entity furnishes a 2019 Form 1095-B to any responsible individual upon request within 30 days of the date the request is received.

Due to the combined reporting requirements under §6055 and §6056 for Form 1095-C for full-time employees of applicable large employer members enrolled in self-insured health plans, the penalty relief doesn’t extend to the requirement to provide Form 1095-C to full-time employees.

Effect on Individual Taxpayers

Due to the extension, individuals might not receive this form by the time they file their 2019 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. Taxpayers don’t need to amend their returns once they receive Form 1095-C, but they should keep the form with their tax records.

Reach out to your BKD trusted advisor or complete the Contact Us form below if you have questions or need assistance in completing the ACA 2019 forms.

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