November 21, 2016- Compliance Observer Alert- Welcome Extension for Furnishing ACA Statements and Penalty Relief

Compl Obs Header Alert_2016

Welcome Extension for Furnishing

ACA Statements and Penalty Relief

 The IRS has extended the deadline for furnishing individual statements under Sections 6055 and 6056 for 2016 and has also extended good-faith transition relief from penalties related to 2016 information reporting under Sections 6055 and 6056.

Announced in NOTICE 2016-70, the IRS extended the due date for furnishing to individuals the 2016 Form 1095-B, Health Coverage, and the 2016 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, from January 31, 2017, to March 2, 2017.  The notice also provides for transitional good-faith relief from the penalties imposed by sections 6721 and 6722 of the Internal Revenue Code relating to the 2016 information reporting requirements under sections 6055 and 6056.  The notice does not however extend the deadline for filing ACA forms with the IRS.

Filers are not required to submit any request or other documentation to the IRS to take advantage of the extended deadline for furnishing the individual statements. Since this extended deadline applies automatically to all reporting entities, the IRS will not grant additional extensions of time to furnish Forms 1095-B and 1095-C. As a result, the IRS will not formally respond to any requests that have already been submitted for 30-day extensions of time to furnish statements for 2016.


As mentioned, the IRS does not feel that filers need additional time to submit their Section 6055 and 6056 reporting to the IRS. Therefore the deadline for filing Forms 1094-B, 1095-B, 1094-C and 1095-C with the IRS remains:

  • Feb. 28, 2017, if filing on paper; or
  • March 31, 2017, if filing electronically

Because the due dates are unchanged, potential automatic extensions of time for filing information returns are still available under the normal rules by submitting a Form 8809. The notice also does not affect the rules regarding additional extensions of time to file under certain hardship conditions.


Individuals do not need to wait to receive Forms 1095-B and 1095-C before filing their returns. Taxpayers may rely on other information received from their employer or other coverage provider for purposes of filing their returns. In addition, individuals do not need to send forms or other information to the IRS when filing their returns, but should keep these items with their tax records.


As with the 2015 returns, the IRS has once again extended transition relief for providing incorrect or incomplete information to reporting entities that can show that they have made good-faith efforts to comply with the Sections 6055 and 6056 reporting requirements for 2016 (both for furnishing to individuals and for filing with the IRS).

This relief applies to missing and inaccurate taxpayer identification numbers and dates of birth, as well as other information required on the return or statement. No relief is provided however for reporting entities that:

  • Do not make a good-faith effort to comply with the regulations; or
  • Fail to file an information return or furnish a statement by the due dates (as extended).

Please contact your local member of the AssuredPartners benefit team if you have questions or need assistance with this or other compliance matters.

AssuredPartners, Inc. and its partner agencies strive to provide you with insurance and benefit related information as part of our service to you that is both accurate and informative. Laws, regulations and circumstances change frequently, and similar situations or slight changes to laws and regulations can lead to entirely different results. The information contained in this document is for educational and informational purposes only, and, as such, you should always seek the advice of competent legal counsel for answers to your specific questions.

Share This: