2015 was a year of firsts. The first official filing of the Affordable Care Act Forms. The first year for the 1094 transmittal. The first year form the 1095. As you may recall, the IRS made some changes to deadlines. They extended the due date for both the recipient forms and the submission to the IRS by three months.
For 2016, the IRS is again modifying due dates for these forms.
Recipient due date changed
This year, though, only the recipient due date has changed. The IRS moved the due date for the 1095 forms by 30 days. The new due date is now March 2, 2017. The IRS recommends sending recipient statements as soon as possible. The extended deadline gives a little more leeway, if needed.
IRS filing dates remain the same
IRS submission deadlines vary based on the filing method.
- Paper filing – the submission is due February 28, including the 1094 transmittal.
- Electronic filing – the submission is due March 31, including the 1094 transmittal.
File on Time
The IRS provided “Good Faith Transition Relief” in the first year of ACA filing. The IRS understands that employers need time to adjust. The IRS provided the transition relief from penalties for filers who could show they made good faith effort to be compliant.
For 2016, the IRS is extending that transition relief when the filing is made in a timely manner.
Future years
Given political changes, no one knows what the future may hold for the ACA. Other information returns may also undergo changes in the coming years. Be sure to remain in compliance with the applicable regulations.
Our recommendation
As much as possible, try to send the recipient copies before the deadline. There are now 30 extra days to do that, but begin collecting the information as soon as possible. You can track most of the required information monthly. Tracking hours worked and coverage offered will make for an easier filing process. If you track that way, you minimize the data collection effort required in January.
Send recipient statements and file to the IRS in a timely fashion. The transition relief does not cover late filings. The relief only covers incomplete and/or incorrect information. There is no need to court a late filing penalty over a concern that some employees’ SSN’s or DOB’s may be wrong. Submit the filing and continue to collect information. Consult IRS publication 1586 for more on avoiding penalties and collecting employee data.
Bottom line: File on time!
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