Applicable large employers and providers of minimum essential coverage (e.g., sponsors of self-insured plans) must now provide to individuals Forms 1095-B (Health Coverage) and 1095-C (Employer-Provided Health Insurance Offer and Coverage) by March 2, 2017, as opposed to the earlier date of January 31, 2017. The date for filing with the IRS remains the same (February 28, 2017, or March 31, 2017, if filing electronically).
Additionally, Notice 2016-70 provides the following:
- The extension is automatic and does not require any request or submission be made to the IRS. As a result, the IRS will not be responding to any previously submitted extension requests.
- Taxpayers will be able to file their returns without waiting for Forms 1095-B and 1095-C.
- The IRS will continue to apply penalty relief for incorrect or incomplete reporting as long as the reporting entity made a good-faith effort to comply and actually furnished the statement to the individual and filed with the IRS.
If you have any questions about this alert, please do not hesitate to contact the authors or your usual Drinker Biddle contact.