Notice 2016-4: Extended due dates, health care coverage information reporting

Extended due dates, health care coverage reporting

The IRS issued an advance version of Notice 2016-4 that extends the due dates for the 2015 information reporting requirements with respect to health care coverage.

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According to Notice 2016-4 [PDF 163 KB], based on comments provided by stakeholders, the IRS and Treasury Department determined that certain employers, insurers, and other providers of minimum essential coverage needed additional time to adapt and implement systems and procedures to gather, analyze, and report this information. Accordingly, Notice 2016-4 provides:

  • The due date for providing information to individuals on Form 1095-B, Health Coverage, and on Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, is extended from February 1, 2016, to March 31, 2016.
  • The due dates for filing information with the IRS on Form 1094-B, Transmittal of Health Coverage Information Returns, on Form 1095-B, Health Coverage, on Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, and on Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, is extended from February 29, 2016, to May 31, 2016, if not filing electronically, and from March 31, 2016, to June 30, 2016, if filing electronically.

Notice 2016-4 also provides guidance to individuals who, as a result of these extensions, may not receive a Form 1095-B or Form 1095-C by the time they file their 2015 individual income tax returns. The guidance explains that these individuals do not need to file this information with the IRS, but need to keep it with their income tax records.

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