Last year, when the IRS finalized their 6055/56 penalties the clear message was simple: “Just file and you will be OK.” Even if your forms were not coded perfectly, you want to make sure your file to avoid the jaw-dropping $500 per form with no cap penalty. So employers that were holding out in late December for some additional change in the law seemed to be playing with fire.
But, on Monday Dec. 28, we received the news that the IRS has delayed the ACA filing and distribution of forms by two to three months for the three requirements:
1) Mail 1095 forms to employees has moved from Jan. 31 to March 31.
2) Paper file 1094/1095 to IRS has moved from Feb. 28 to May 31.
3) Electronic file 1094/1095 to IRS has moved from March 31 to June 30.
Those employers truly dodged a bullet. There are a couple advantages for starting this late in the game. First of all, late entrants in ACA filing will begin the process with a full year of data and they benefit from the lessons of early adopters. We have found late entrants to be less challenging to implement than we expected.
Also see: "How employers are controlling healthcare costs."
On the flip side, employees, especially those who file their taxes early, are going to be clamoring for their 1095-C form. While this form is not required to be submitted like a 1099 or W2, it will still be needed by your tax preparer to verify eligibility of subsidies (if requested) or to prove that you and your dependents had coverage (in the case of covered individual section of the C and B forms).
So, don’t wait too much longer.
Weiskirch is principal at EmployeeTech, Inc. Reach him at (847) 236-1932 or firstname.lastname@example.org.
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