Form 1095-C Furnishing Deadline Extended by IRS

The recent IRS Notice 2020-76 provides important updates for Applicable Large Employers (ALEs) regarding their responsibilities under the Affordable Care Act (ACA). ALEs, or employers who had at least 50 full time equivalent employees in the previous calendar year, are required to furnish Form 1095-C to its current and past employees each year. Notice 2020-76 extended the 2021 deadline for furnishing Forms 1095-B and 1095-C from January 31^st, 2021, to March 2^nd, 2021.

It’s important to note that the form deadline extension applies to furnishing but not filing. The filing deadline for Forms 1094-B, 1095-B, 1094-C, and 1095-C with the IRS remains February 28^th, 2021, if filing by paper and March 31^st, 2021, if filing electronically. Sections 6055 and 6056 provide the IRS with the ability to grant extensions of up to 30 days for furnishing Forms 1095-B and 1095-C when good cause is demonstrated. However, the IRS still encourages employers to furnish the required forms as soon as possible.

Now more than ever, ALEs must be especially careful and diligent when complying with their ACA responsibilities. The IRS Affordable Care Act Enforcement Office has recently begun sending Letters 5699 to non-filers for the 2018 tax year. If it is determined an employer was supposed to file but didn’t, an IRS Letter 226J is sent that gives an assessment of noncompliance and a proposed penalty amount. In the past, noncompliant employers have been able to apply for penalty relief if they’ve shown a good-faith effort to fulfill their furnishing and filing duties. While this relief option still applies for the 2020 reporting year, Notice 2020-76 states that this is the final year this relief will be available.

Employers looking to reduce their compliance risk should look no further than BASIC’s ACA Elevate. Our ACA compliance service offers peace of mind with access to robust materials prepared by compliance experts, file-ready Form 1095 generation, automatic e-Filing to the IRS, plus optional ACA corrections transmittal and mailing Form 1095-Cs directly to employees for ease of distribution. BASIC can handle preparation of Form 1094-C and Form 1095-C with e-Filing for employers of all sizes and complexity– we’ve furnished over 1,000,000 1095-C Forms since 2015! The online ACA portal provides a variety of training videos and materials employers can access at any time.

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