The Internal Revenue Service (IRS) released guidance in the form of Notice 2018-94 allowing employers more time to provide Forms 1095-B and 1095-C to applicable individuals. Employers now have until March 4, 2019 to furnish forms to employees. Despite the additional time, the IRS encourages employers to furnish 2018 statements as soon as they are able. The same Notice confirmed that due dates for filing these same forms with the IRS will not be extended. Employers that electronically file are still required to file their ACA information reporting forms by April 1, 2019.

Additionally, the IRS has provided transitional good-faith relief from sections 6721 and 6722 reporting penalties related to ACA reporting. This relief applies to incorrect or incomplete information as it relates to inaccurate taxpayer identification number (TINs) and dates of birth. However, if an employer fails to file information with the IRS, or to provide required forms to employees by the stated deadlines, then this same relief will not apply.

Lastly, the IRS is examining how ACA reporting requirements should change, if at all, in future years with the individual mandate penalty reducing to zero. If you have any questions about this extension, or any other ACA topic, please contact your First Advantage account manager or your legal counsel. First Advantage will stay abreast of any future updates and continue to keep you informed of the ever evolving healthcare landscape.