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ACA Reporting Extension

Posted on November 30th, 2016

The Internal Revenue Service (IRS) issued Notice 2016-70 on November 18, 2016 which provides some relief to insurers, employers and other entities subject to ACA reporting requirements under Code Section 6055 and 6056. The Notice does not extend the due date of the filing requirement for the 2016 year, but it does extend the due date in which copies of the reporting forms must be provided to employees and individuals. The due dates are now as follows:
  • Copies of the applicable Form 1095 must be provided to employees and individuals no later than March 2, 2017 (previously January 31, 2017).
  • If filing manually, reporting must be submitted to the IRS no later than February 28, 2017.
  • If filing electronically, reporting must be submitted to the IRS no later than March 31, 2017. Electronic filing is required for entities who submit 250 or more Form 1095s.
The Notice also extends the good-faith transition relief to the 2016 reporting year. Generally, this means insurers and employers will not be subject to penalties if they complete their reporting obligations by the deadline, but some of the forms are incomplete or inaccurate. However, penalties would still most likely apply if an entity failed to complete the reporting by the deadline. 
The IRS indicates at the conclusion of the Notice that they do not expect to extend any deadlines for the 2017 reporting year nor do they expect to extend good-faith transition relief to any future years. 

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