2018 ACA Extension of Due Date for Furnishing Statements

Furnishing Deadlines Extended

This week, the Internal Revenue Service released Notice 2018-94, which extends the due dates for furnishing the 2018 ACA Reporting Forms 1095-B and Form 1095-C to employees. This extension allows for an additional 30 days for both employers and health insurance providers to provide the Forms 1095 to employees and individuals enrolled in coverage, moving the due date from January 31, 2019 to March 4, 2019.  The extensions of due dates apply only to information statements (Forms 1095-B and 1095-C) for calendar year 2018 furnished in 2019.

This notice also extends good-faith transition relief from section 6721 and 6722 penalties to the 2018 information-reporting requirements under sections 6055 and 6056.

Please note that this notice does not extend the filling due dates for the Employer Copies of the 2018 Forms. The deadlines to file the Forms 1094 and 1095 with the IRS remain unchanged, with those dates detailed below.

 Filing Deadlines Remain Unchanged

• The due date for health coverage providers and employers filing the 2018 Forms 1094/1095-B and the Forms 1094/1095-C to the IRS is February 28, 2019, if not filing electronically. This date is not extended.
• The due date for health coverage providers and employers electronically filing the 2018 Forms 1094/1095-B and the Forms 1094/1095-C to the IRS is April 1, 2019. This date is not extended.

Next Steps

Paylocity has taken into consideration the IRS extension and after evaluating the current status of our ACA customers, we will proceed as follows:

• Paylocity will continue to produce forms 1095-C in early January as originally planned.
• If our clients need to take advantage of the extension, Paylocity will be able to reprint forms once all necessary updates have been made by the client.
• Paylocity will accept reprint requests through February 15th, but we encourage all of our clients to take care of this as early as possible to ensure their employees have the forms for their own personal tax filings.

Transition Relief Extended

Notice 2018-94 also extends transition relief from penalties for incorrect or incomplete data reported on the information returns to reporting entities who make a good faith effort to meet the information reporting requirements. This relief will now be extended for tax year 2018. There is no transition relief available to those that do not make a good faith effort to comply or fail to file or furnish the information returns by the due dates. To view IRS Notice 2018-94 in detail: https://www.irs.gov/pub/irs-drop/n-18-94.pdf

A Note about Individual Tax Returns

Some employees may not receive their other Forms 1095, such as 1095-B from their health insurance provider, prior to filing their personal income tax returns. Individuals may rely on other information received from their employer or other coverage providers for the purposes of determining premium tax credit eligibility upon filing their income tax returns and confirming that they had minimum essential coverage. Individuals do not need to wait to receive Forms 1095-B and/or 1095-C prior to filing their returns.

Thank you for choosing Paylocity as your Payroll Tax and Human Capital management partner.

This information is provided as a courtesy, may change and is not intended as legal or tax guidance. Employers with questions or concerns outside the scope of a Payroll Service Provider are encouraged to seek the advice of a qualified CPA, Tax Attorney or Advisor.