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Post Date:  1/18/2016
Last Updated:  1/18/2016

Summary
Cross References
- Notice 2016-4

Under the Patient Protection and Affordable Care Act (ACA), health insurance issuers, self-insuring employers, government agencies, and other providers of minimum essential coverage are required to furnish Form 1095-B, Health Coverage, to individuals receiving the health insurance coverage by February 1, 2016, for the 2015 coverage period. Form 1095-B is then used by the individual to prove which months during 2015 he or she received minimum essential coverage, as well as all other covered individuals under the same policy.

Likewise, applicable large employers (generally those with 50 or more full-time employees) are required to furnish Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, to their employees by February 1, 2016 for the 2015 coverage period. Form 1095-C is then used by the employee to prove which months during 2015 he or she received minimum essential coverage from the employer. The form also provides the employee information on which months the employer offered coverage and whether or not that coverage was affordable. The employee in turn does not qualify for the premium tax credit for any month the employer offered affordable coverage, even if the employee refuses employer coverage and purchases health insurance through the Marketplace.

Both Form 1095-B and Form 1095-C provide essential information needed to prepare a correct individual tax return for 2015. For example, Form 1095-B can be used to prove the taxpayer is not subject to the Shared Responsibility Payment, Form 1040, line 61. Likewise, Form 1095-C can be used to determine which months an employee does not qualify for the Premium Tax Credit (Form 8962) because of being offered affordable coverage from the employer.

The IRS recently determined that some employers, insurers, and other providers of minimum essential coverage need additional time to adapt and implement systems and procedures to gather, analyze, and report information required to be reported on these forms. Therefore, the IRS has extended the due dates for furnishing these forms to recipients from February 1, 2016 to March 31, 2016. The extended due date also applies to the requirement to file these forms with the IRS, as well as their corresponding transmittal forms (Form 1094-B and Form 1094-C).

The due date extension does not apply to Form 1095-A, Health Insurance Marketplace Statement, which is furnished by the Marketplace to individuals who purchased their health insurance through the Marketplace.

Due date extension does not delay filing Form 1040. The notice specifically tells individuals that they may rely upon other information to file their tax returns before receiving Form 1095-B and/or Form 1095-C, and that they need not amend their returns once they receive their Form 1095-B and/or Form 1095-C (or any corrected Form 1095-B and/or Form 1095-C). The notice makes clear that this provision applies for the 2015 tax year only and not to any future year.

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