The IRS released Notice 2018-94 that extends the deadline for Applicable Large Employers (ALEs) to furnish Forms 1095-C and 1095-B to individuals with 2018 calendar year information. The new deadline is March 4, 2019 (instead of January 31, 2019). The deadline to provide the required forms to the IRS remain unchanged – February 28, 2019 if by paper or April 1, 2019 for electronic filing (which is required for 250 or more forms).

The notice is similar to those issued to extend prior years’ reporting deadlines and includes an extension of the good-faith transition relief applicable to incorrect and incomplete reporting. The IRS determines good faith based on the employer’s reasonable efforts to prepare and furnish the information.

Although the good-faith transition relief does not apply to failure to timely file or furnish the forms, employers who miss a deadline are encouraged to provide the forms as soon as possible. The IRS will take into account late filings and furnishings when determining whether to assess or reduce the penalties for reasonable cause.

Lastly, the notice acknowledges that the IRS and Department of Treasury are considering whether to the change the reporting requirements for future years due to the elimination of Affordable Care Act’s (ACA) individual mandate penalty which is effective January 1, 2019.

Our bulletin (read here) contains additional information on ACA’s reporting requirements. Note: It has not been updated with the above-stated extensions.

If you have questions or need help, please contact one of our benefits consultants.