Extension of the Due Dates for 2015 Reporting Under I.R.C. Section 6055 and 6056

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Executive Summary

    • The Federal Government has delayed the Employer Reporting Requirements for the 2015 calendar year information.
    • Now, employers may distribute Form 1095-C to employees as late as March 31, 2016, instead of the original due date of February 1, 2016.
    • Form 1094-C and 1095-C previously needed to be delivered to the IRS in paper form by February 29, 2016. However, the paper delivery method has been extended to May 31, 2016.
    • Electronic transmittal of the 1094-C and 1095-C to the IRS can now be transmitted as late as June 30, 2016, rather than the original due date of March 31, 2016.

Employer Reporting Requirement extension outlined in Notice 2016-4

IRS Notice 2016-4 extends the due dates for 2016 information reporting requirements for insurers, self-insuring employers and certain other providers of minimum essential coverage under section 6055 of the Internal Revenue Code (IRC) and the information reporting requirements for applicable large employers under section 6056 of the IRC.

Specifically, the notice extends the due date for (1) furnishing individuals the 2015 Form 1095-B, Health Coverage, and the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, from February 1, 2016, to March 31, 2016, as well as (2) filing with the IRS the 2015 Form 1094-B, Transmittal of Health Coverage Information Returns, the 2015 Form 1095-B, Health Coverage, the 2015 Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer of Coverage Information Returns, and the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, from Feburary 29, 2016 to May 31, 2016, if not filing electronically and from March 31, 2016 to June 30, 2016 if filing electronically. This notice also provides guidance to individuals who might not receive a Form 1095-B or Form 1095-C by the time they file their 2015 tax returns.

Next Steps for Employers

While the IRS is prepared to begin accepting filings of information returns on Forms 1094-B, 1095-B, 1094-C and 1095-C beginning in January 2016, employers may find relief with these extensions. Employers are still encouraged to furnish statements and file the information returns as soon as they are ready.

For further review of Notice 2016-4: https://www.irs.gov/pub/irs-drop/n-16-4.pdf


Christopher K. Bao, Esq.
Regulatory Compliance Manager Employee Benefits Compliance & Regulatory Affairs, MMA West
(949) 540-6924

About Barney & Barney

Barney & Barney is one of the nation’s leading insurance brokerages, offering a comprehensive line of risk management and employee benefit solutions. The firm specializes in commercial property and casualty insurance, employee benefits, workers’ compensation, compensation consulting, executive liability, personal lines and surety. In 2014, Barney & Barney joined Marsh & McLennan Agency LLC (MMA), a subsidiary of Marsh Inc., the world’s leading insurance broker and risk advisor. Barney & Barney has offices in San Diego, San Francisco, Oakland and Orange County. For more information, visit www.barneyandbarney.com, or call 800.321.4696.