For the third consecutive year, the IRS has extended by 30 days the deadline for health plan sponsors to furnish Forms 1095-B and 1095-C to individuals. A 30-day extension would place the deadline on a Saturday, so this year’s reprieve will allow employers, health insurers, and other plan sponsors to distribute the forms on or before March 4, 2019, rather than January 31.

The new guidance does not extend the deadlines for submitting the forms, along with Forms 1094-C and 1094-B, to the IRS. Those deadlines remain February 28, 2019, for paper forms and March 31, 2019, for electronic filings. Those submitting paper forms should take note that the IRS filing deadline precedes the date for providing the forms to individuals.

Also following prior years’ guidance, the IRS has extended good-faith relief to filers who submit incomplete or incorrect information in their 2018 Forms 1094 and 1095. To qualify for this relief, the reporting entity must show that it made good-faith efforts to comply with requirements. However, this relief does not cover a missed deadline for reporting.

Employers should be prepared to respond to inquiries about coverage from employees who are filing their tax returns for 2018 early and may wish to keep in mind that the legislative repeal of the individual mandate assessments under the ACA does not take effect until 2019.

The forms and instructions for reporting on the 2018 year include:

Ballard Spahr attorneys established the Health Care Reform Initiative to monitor and analyze legislative and regulatory developments in health care reform. We will continue to follow developments in this area as they emerge. Our Health Care Reform Dashboard serves as an ongoing online resource center for news and analysis on developments regarding the ACA and health care reforms that follow.

Attorneys in Ballard Spahr’s Employee Benefits and Executive Compensation Group help clients design and implement compensation and benefits packages that comply with today’s complex regulatory requirements, attract and retain a quality workforce, and maintain fiscal and fiduciary responsibility. Attorneys in Ballard Spahr’s Health Care Group represent clients across the health care industry and counsel clients on health care, benefits, and tax regulatory and compliance issues, as well as privacy and data security, transactional, financing, benefits and compensation, and labor and employment matters.


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