On December 28, 2015, the IRS announced an automatic extension of the Affordable Care Act reporting deadlines for distributing and/or filing the 1094-B/1095-B and 1094-C/1095-C forms. This relief only applies for the 2015 calendar year.

For employers who were considered applicable large employer members (“ALE members”) in 2015, the new deadline for furnishing your full-time employees the 1095-C forms is extended from February 1, 2016 to March 31, 2016. March 31, 2016 is also the new deadline for non-ALE members who sponsored self-insured group health coverage to distribute the 1095-B forms to employees who enrolled and were eligible for benefits for one or more months in 2015.

The deadline for filing these with the IRS by paper (along with the applicable 1094 form) is extended from February 29, 2016 to May 31, 2016. If you choose or are required to electronically file these forms (i.e., you are filing 250 or more 1095 forms for 2015), the filing deadline is extended from March 31, 2016 to June 30, 2016.

While the extensions give employers more time to complete the required forms, we recommend distributing the 1095 forms to employees by February 1, 2016 to the extent possible so employees can provide accurate data to the IRS when they file their individual income tax returns. The IRS announced that individuals need not wait to receive the 1095 forms before filing their individual income tax returns. However, by doing so, there is a heightened risk that employees may report inaccurate information about their coverage or eligibility for a premium tax credit and the IRS is likely to put the burden on the employer to explain any discrepancies. If you don’t think you will be able to distribute the 1095 forms by the end of January, you might consider sending employees who were eligible for and/or who enrolled in coverage a separate informational notice about their coverage so they can accurately complete their tax returns by the April 15th deadline.