Skip to main content
Article | Insider

IRS delays due date for 2020 ACA reporting

Benefits Administration and Outsourcing|Health and Benefits|Total Rewards
N/A

By Maureen Gammon and Kathleen Rosenow | October 14, 2020

The IRS has extended the due date for certain 2020 Affordable Care Act information reporting filings from February 1, 2021, to March 2, 2021.

In Notice 2020-76, the IRS has extended the due date for certain 2020 Affordable Care Act (ACA) information reporting filings from February 1, 2021,1 to March 2, 2021. Specifically, the delayed due date applies to furnishing 2020 Form 1095-B, Health Coverage, and Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, to individuals. While the IRS is otherwise allowed to grant extensions of up to 30 days to furnish these forms to individuals, the notice states that the IRS will not extend the due date beyond March 2, 2021.

Notwithstanding the extension provided in the notice, the IRS encourages employers and other coverage providers to furnish 2020 statements as soon as they are able.

The notice does not extend the due date for filing the 2020 ACA information reporting forms with the IRS, including Form 1094-B, Transmittal of Health Coverage Information Returns; Form 1095-B, Health Coverage; Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns; and Form 1095-C, Employer-Provided Health Insurance Offer and Coverage. That deadline is March 31, 2021 (if filing electronically), and March 1, 20212 (if not filing electronically).

The notice also provides relief from the reporting penalty for failure to provide a Form 1095-B to individuals enrolled in a fully insured plan, and failure to provide a Form 1095-C to individuals who were enrolled in a self-insured plan but were not an ACA full-time employee for any month in 2020, subject to the following two conditions:

  1. The employer must post a notice on its website stating that individuals can receive a copy of their 2020 Form 1095-B or 1095-C (as applicable) upon request. The notice must be accompanied by an email address and a physical address, as well as a telephone number, of the reporting entity/applicable large employer that the individual can contact with questions.
  2. The reporting entity/applicable large employer must furnish a 2020 Form 1095-B or 1095-C (as applicable) to an individual within 30 days of the date the request is received.

Finally, the notice provides for transitional good-faith relief from the penalties imposed by Internal Revenue Code sections 6721 and 6722 relating to the 2020 ACA information reporting requirements. The good-faith transition relief applies to incorrect or incomplete information, such as missing and inaccurate taxpayer identification numbers and dates of birth, as well as other information required on the return or statement. To be eligible for the relief, reporting entities must make a good-faith effort to comply and file a return or furnish a statement by the extended due dates provided in the notice. The notice also indicates that this is the last year that the IRS intends to provide this relief.

Footnotes

1 Because the regular due date, January 31, 2021, falls on a Sunday, the due date became February 1, 2021.

2 Because the regular due date, February 28, 2021, falls on a Sunday, the due date became March 1, 2021.

Authors

Senior Regulatory Advisor, Health and Benefits

Senior Regulatory Advisor, Health and Benefits

Contact Us