Employers seeking deadline extensions for filing the Affordable Care Act’s reporting forms have been granted last-minute relief by the IRS in the form of Notice 2016-4. The notice, issued on Dec. 28, 2015, extends due dates for employers subject to to the following reporting deadlines:

Previous IRS Due Date New IRS Due Date
Forms 1095-B and 1095-C were due to individuals by Feb.1, 2016 March 31, 2016
Forms 1094-B, 1095-B, 1094-C and 1095-C were required to be filed with the IRS if filing on paper by Feb. 29, 2016 May 31, 2016
Forms 1094-B, 1095-B, 1094-C, and 1095-C were required to be filed with the IRS if filing electronically by March 31, 2016 June 30, 2016
Source: ADP, based on IRS Notice 2016-4.

Prior to the deadlines being adjusted, employers had been rallying for extensions due to the late release of filing instructions in 2015.

According to HR experts, the logistical challenges of obtaining the necessary data to complete the forms are immense.

“The data that needs to be reported — particularly on the Form 1095-C — relates to information that many employers did not previously maintain in a format that facilitated reporting,” says Kathryn Wilber, Senior Counsel for Health Policy at the American Benefits Council. “As a result, employers’ attempts to establish systems that can accommodate the reporting requirements have generated logistical complications and we continue to hear about new difficulties from employers on a regular basis.”

In order to complete the required forms, employers will need to be resourceful and take on a decent amount of administrative work. The breadth of information both employers and employees are responsible for providing is in-depth and highly specific,  according to Chartrand Birbal, Senior Advisor for Government Relations at the Society for Human Resource Management.

“This information is not contained in a central repository,” says Birbal. “Most employers will have to use multiple sources to obtain the data necessary to complete the reporting forms, including their benefits carrier or broker, HR information system, payroll company, time-off tracking software, and other sources.”

Regardless of size, all self-insured employers in 2015 are required to report coverage information about enrollees to show compliance in providing minimum essential coverage. ALEs with 50 or more full-time and full-time equivalent employees are subject to additional reporting requirements, which can be viewed here.

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