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Healthcare Reporting Deadline Pushed Back: What To Do Now

The biggest takeaway from this news is to continue the work you have been doing toward ACA compliance. The extension and good faith effort measures allow for a little breathing room, but it’s imperative that you stay the course.

Nov. 22, 2016

The IRS released Notice 2016-70 regarding ACA Information Reporting (§6055 and §6056) on Friday, Nov. 18, which granted the following:

  • An automatic 30-day extension for 1095-C employee fulfillment. The deadline was moved from Jan. 31, 2017 to March 2, 2017. Take note: Both the mail and electronic filing deadlines are NOT extended. The mail filing deadline remains Feb. 28, 2017 and the e-filing deadline remains March 31, 2017.
  • An extension of the “good faith effort” standard for applicable large employers. This is the same transition relief offered for 2015 reporting that made it a preseason to full ACA compliance.

So what does this mean for you?

Just like last year, the good faith effort standard means the IRS will be more lenient with incorrect and incomplete information reported on the 1094 and 1095 series forms. This does not mean that an employer can skip fulfillment and filing these forms altogether. Employers must provide employees with the 1095-C and file with the IRS, file on time, and make every effort to get it right, but if the information reported on the forms is incorrect, they will be shielded from penalties. 

The biggest takeaway from this news is to continue the work you have been doing toward ACA compliance. The extension and good faith effort measures allow for a little breathing room, but it’s imperative that you stay the course.

This announcement is really separate from the election’s potential effect on the ACA. Instead, it’s intended to make sure that issues involving employee information, such as inaccurate taxpayer identification numbers or dates of birth, do not interfere with a business’s intent to reach compliance. One way to prove you’re truly making a good faith effort is simply by gathering what data you have and transferring it to a system that can prepare your data for proper delivery to the IRS.

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Arthur Tacchino is Principal and the Chief Innovation Officer at SyncStream Solutions (www.sync-stream.com), an ACA reporting and compliance company.