Yesterday, the IRS released Notice 2016-4, extending the deadlines for providing the 1095-C form to employees and filing the 1094-C/1095-C with the IRS.
The old deadline for providing the 1095-C form to employees was February 1, 2016. The new deadline is March 31, 2016, giving employers an additional 2 months. (Note: if you planned on mailing the 1095-C with the employees’ W-2, the deadline for providing W-2’s has not changed. Therefore, you will either need to stick to the original deadline to mail the forms together, or mail them separately.)
The old deadline for filing the 1094-C and 1095-C on paper with the IRS was February 29, 2016. The new deadline is May 31, 2016, giving employers an additional 3 months.
The old deadline for filing the 1094-C and 1095-C electronically with the IRS was March 31, 2016. The new deadline is June 30, 2016, also giving employers an additional 3 months.
These extensions are automatic and do not require filing an application.
If you have not been using the HR software for the entire year, or are transitioning from another payroll/accounting system to Datatech’s software, this will provide you with additional time to import/enter data, compile information and review the forms for accuracy.
ACA Reporting Status in HR
The current release of the HR program includes the Compile 1095-C Information option with the updated logic needed to automatically assign Series 1 and 2 codes for each month when using the the monthly measurement period. (Previously releases of the HR program only included a preliminary Compile option that was meant for testing.) We expect to complete the logic for the look-back measurement period this week, and have a new version that includes this ready for download early next week.
If you have not already done so, review the “Preparing for 1095-C reporting” series of articles (1, 2, 3, 4) on our blog that were published earlier this month, then review the following topics in the online help for the HR program:
Compile 1095-C Information
Enter/Edit Form 1095-C
Print 1095-C Reports
The Compile 1095-C Information includes sub-topics discussing the logic used to assign the series 1 and 2 codes and codes that may be open to interpretation. (The next post on our “Preparing for 1095-C reporting” series will cover these topics and summarize much of the information that is already published in the help file.)
A video is also planned showing how the 1095-C options work as well as how to review and check the results of the Compile process.
Transitioning Methods
Employers that are transitioning from the monthly measurement period to the look-back measurement period may need some additional logic added to the 1095-C reporting to determine the applicable Series 2 codes during the transition period. We will provide additional information on this next week.
Offers of Coverage During Open Enrollment
Some additional logic may be added to the program to handle offers of coverage during an open enrollment period (as opposed to an offer of coverage when an employee becomes eligible). This may depend on whether or not a health benefit record was entered for every employee offered coverage during the open enrollment period. The instructions provided by the IRS for the 1095-C do not explain how these offers should be reported. We are reviewing information from the IRS and will provide an update on this.
Electronic Reporting
The IRS will begin their “business rule” testing of the electronic 1094-C/1095-C files in January. We will be submitting test files as soon as this testing period opens to get our software certified for electronic reporting. An update will be released to the HR program when the testing phase has been completed. Until then, the Generate Electronic Files option will only create a test file.