Pension & Benefits News IRS extends filing deadlines, penalty relief for health coverage reporting forms
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Monday, December 9, 2019

IRS extends filing deadlines, penalty relief for health coverage reporting forms

By Pension and Benefits Editorial Staff

In Notice 2019-63, the IRS automatically extends the due date for furnishing individuals with the 2019 Form 1095-B, Health Coverage, and the 2019 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, to March 2, 2020 from January 31, 2020. Like the automatic extension granted for prior-year information returns, the IRS will not entertain any requests for further extensions of this new, blanket deadline.

As in 2018, the IRS did not extend the due dates for filing the 2019 Form 1094-B, Transmittal of Health Coverage Information Returns, and the 2019 Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer. Those dates remain February 28, 2020, for those filing less than 250 forms on paper, and March 31, 2020, for those filing electronically. Filers may, however, request an automatic 30-day extension of those filing deadlines.

Penalty relief. In addition, the IRS has again stated that accuracy-related penalties will not be imposed on health insurers and employers that make a good faith effort to comply with the reporting requirements, provided they furnished statements to individuals and filed with the IRS on a timely basis.

In contrast to prior years, the IRS will waive penalties for failing to furnish certain forms when employers and health insurers meet defined requirements. In light of the individual shared responsibility payment (i.e., individual mandate penalty) being reduced to $0 beginning in 2019, the Notice recognizes that “an individual does not need the information on Form 1095-B in order to compute his or her federal tax liability or file an income tax return with the Service.” Accordingly, employers and health insurers will not be assessed penalties for failure to furnish Forms 1095-B (which they generally issue to report enrollment of responsible individuals who are not full-time employees) if they meet two conditions: (1) the reporting entity must post a notice prominently on its website stating that individuals may receive a copy of the form on request; and (2) the reporting entity must furnish the form within 30 days of receiving that request.

Penalty relief also applies to applicable large employers (ALEs) that use Forms 1095-C to report enrollment in Part III to anyone who is not a full-time employee for any month in 2019. This relief does not otherwise extend to ALEs for the Forms 1095-C they must furnish to employees who meet the definition of “full-time” for any month during 2019.

While employers and insurers may have penalty relief for failing to furnish certain forms, they must still file these forms with the IRS. In addition, they must now furnish 2019 forms to individuals who are subject to individual mandate legislation in New Jersey and the District of Columbia despite the IRS waiving the penalties for failure to furnish at the federal level.

Comments requested. Finally, the Notice requests comments on whether and why the IRS should extend future deadlines for furnishing forms to individuals. Comments are also requested on whether and why good-faith reporting relief should be provided in the future. Comments can be submitted electronically via the Federal eRulemaking Portal at www.regulations.gov; or by mail to: IRS, Attn: CC:PA:LPD:PR (Notice 2019-63), Room 5203, P.O. Box 7604, Ben Franklin Station Washington, D.C. 20044.

SOURCE: Notice 2019-63, I.R.B. 2109.-51, December 16, 2019.

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