In its most recent set of proposed regulations on the Affordable Care Act (ACA), the IRS included several points of relief and clarification regarding the law’s information reporting. Notable highlights for employers and other reporting entities are summarized below.
Permanent Extension of Individual Furnishing Deadline
The proposed regulations provide an automatic 30-day extension of the deadlines for employers and insurers to furnish 1095-B and 1095-C forms to individual recipients. The proposal states that employers and insurers may take advantage of the extension for 2021 reporting forms, due in early 2022, before the rule is finalized.
For 2021 reporting, the previous individual furnishing deadline was January 31, 2022, making the 30-day extension deadline March 2, 2022.
IRS Filing Deadline is Not Extended
The due dates for filing Form 1094-B and Form 1094-C with the IRS are not extended and will remain the same. For 2021, the IRS filing deadlines are: February 28, 2022 if mailed to the IRS, or March 31, 2022 if filing electronically (electronic filing is mandatory for entities with 250+ forms).
Elimination of Transitional Good Faith Relief
The IRS provided a final extension of good faith relief from penalties for certain errors related to 2020 ACA reporting due in 2021, clarifying such relief was intended to be transitional only. In the proposed regulations, the IRS has confirmed this relief is no longer available, and they will no longer grant penalty relief upon showing good-faith efforts to comply.
Marshall & Sterling is here to help! We will be in touch with current ACA clients in the coming weeks with everything needed to accurately and timely complete all applicable reporting. For those still in need of a solution, please reach out to your Group Benefits representative.
Please feel free to contact us with any questions.
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