Affordable Care Act: IRS Extends 2019 Reporting and Filing Deadline

It’s that time of year again. Large employers must turn their attention to the Affordable Care Act’s annual information-reporting requirements. The good news is that the Internal Revenue Service extended the deadline for large employers to furnish 2019 information statements to employees. However, the deadline to file information returns with the IRS has NOT been extended.

Applicable Large Employers, which are generally those with 50 or more full-time or full-time equivalent employees in the previous year, must do the following to comply with the ACA’s 2019 annual reporting requirements.

Furnish Information Statements to Full-Time Employees. The IRS extended the deadline to provide Form 1095-C (Employer-Provided Health Insurance Offer and Coverage) to full-time employees from January 31, 2020 to March 2, 2020. This is the fifth consecutive year that the IRS has extended this deadline.

File Information Returns and Transmittals with the IRS. Every Form 1095-C along with Form 1094-C (Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns) must be filed with the IRS on or before February 28, 2020 (March 31, 2020, if filed electronically). The IRS did NOT extend this filing deadline. However, employers may request an automatic 30-day extension by filing Form 8809 before the ACA filing deadline.

For 2019, the IRS also extended the good-faith relief from penalties that may be levied against employers for failing to properly file or furnish these forms, which can be $270 per form. The maximum penalty can be $3,339,000. To be eligible for this relief, employers must make a good-faith effort to comply.

According to the IRS, this relief applies to missing and inaccurate taxpayer identification numbers and dates of birth, as well as other information required on the return or statement. Employers that fail to file an information return with the IRS or furnish a statement to an employee by the extended deadline are not eligible for the extended the good-faith relief from ACA penalties.

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