The IRS has extended the deadline for furnishing 2016 Forms 1095-C and 1095-B to individuals by 30 days to March 2, 2017. The reprieve offers welcome relief to employers, health insurers, and other plan sponsors who would otherwise have been required to distribute these forms under the Affordable Care Act (ACA) by January 31, 2017.

The IRS did not extend the deadlines to submit the forms, along with Forms 1094-C and 1094-B, to the Service. Those deadlines remain February 28, 2017, for paper forms and March 31, 2017, for electronic filings. Those submitting paper forms should take note that the IRS filing deadline precedes the date for providing the forms to individuals.

The IRS also extends the good faith relief for ACA reporting to the reports prepared for the 2016 year. This extension offers relief for incomplete and incorrect information supplied in Forms 1094 and 1095, where the reporting entity can show that it made good faith efforts to comply with the requirements. This relief does not apply where good faith is not exercised or where a reporting deadline is missed.

With the change in administrations, changes are imminent for the ACA and a range of other laws and regulations affecting health care and health benefits. Ballard Spahr attorneys established the Health Care Reform Initiative to monitor and analyze legislative and regulatory developments. We will continue to follow developments in this area as they emerge. Changes may come to the Health Care Reform Dashboard, but it will continue to serve as an online resource center for news and analysis on developments regarding the ACA and health care reforms that follow.


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