Reporting Deadline for Form 1094-C and Form 1095-C Extended

If you need assistance with the Form 1094-C or Form 1095-C, please contact us at rmoulder@healthcare-attorney.com or 314-698-9057.

At the last minute the IRS has extended the deadline for furnishing the Form 1095-C statements to individuals and the Form 1094-C and Form 1095-C to the IRS for the 2015 calendar year. This is a surprise that should be helpful to employers but also will make the IRS less forgiving of late filers.

Notice 2016-4 provided transition relief for the 1095-C statements that were to be furnished to individuals by February 1, 2016 to a new filing due date of March 31, 2016. The Notice also provided transition relief for the Form 1094-C and 1095-C which are to be provided to the IRS. If an employer is not filing electronically, the due date has been extended from February 29, 2016 to May 31, 2016. If an employer is filing electronically, the due date has been extended from March 31, 2016 to June 30, 2016.

Importantly, the automatic and permissive extensions discussed in the instructions to the Form 1094-C and Form 1095-C no longer apply. Therefore, the March 31, 2016 deadline for furnishing the 1095-C statements is now a hard deadline. Similarly, the May 31, 2016 deadline for employers who are not filing electronically and the June 30, 2016 deadline for employers who are filing electronically are now hard deadlines.

Fortunately, employers who comply with the new deadline will still have the protection for a good faith effort in the 2015 calendar year. The transition relief only applies to the 2015 calendar year. Employers should not anticipate such leniency in future years.

Should you have any additional questions or need assistance finding a provider who performs the Form 1094-C and Form 1095-C services, please contact us.


Legal Consent

The information contained on this site is not, nor is it intended to be, legal advice. An attorney should be consulted for advice regarding your situation.  Copyright © 2015 by Health Care Attorneys PC. All rights reserved. You may reproduce materials available at this site for your own personal use and for non-commercial distribution. All copies must include this copyright statement.