News & Announcements

IRS Gives Applicable Large Employers More Time to Furnish Forms 1095-B and 1095-C

Posted Tuesday, January 9, 2018 6:31 am

The Internal Revenue Service has extended the deadline for issuing Forms 1095-B (Health Coverage) and 1095-C (Employer-Provided Health Insurance Offer and Coverage).  Health insurance issuers and applicable large employers (employers with 50 or more full-time employees, including full-time equivalent employees) that must furnish these forms to individuals now have until March 2, 2018 to provide the required documents.  

IRS Notice 2018-06 pushes back the deadline by 30 days from January 31, 2018 to March 2, 2018.  This is an automatic extension for the information statements reporting on health coverage during calendar year 2017 although the reports are actually furnished in 2018.  The extension does not apply to future filings and does not impact the filing deadline to transmit the reports to IRS.  The deadline to file reports with the IRS remains to be February 28, 2018 (paper) or March 31, 2018 (electronic).

Good Faith Relief

In addition to extending the deadline to furnish Forms 1095-B and 1095-C, Notice 2018-06 also extends for 2017 the good faith transition relief for incorrect and incomplete information reported on the statements or returns required by sections 6055 and 6056 (both for furnishing to individuals and for filing with the IRS).  As with prior years, the good faith transition relief is inapplicable to failing to timely furnish or file a statement or return.

In determining whether “good faith” exists, the IRS will evaluate whether "reasonable efforts" were made to comply with the reporting requirements.  This may include, for instance, whether the employer gathered and transmitted the necessary data to an agent to prepare the reports for filing, whether the employer or agent tested its ability to transmit the information to IRS, and to what extent steps were taken to ensure compliance with the reporting requirements in 2018.

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