Under the Affordable Care Act (“ACA”), the deadline for applicable large employers (“ALEs”) to furnish Form 1095-C and 1095-B to certain individuals (such as full-time employees in the case of Form 1095-C) is January 31 with respect to the preceding calendar year. The Internal Revenue Service (“IRS”) released final regulations on December 12, 2022 with respect to ACA reporting requirements. These final regulations provided an automatic extension of 30 days to furnish these statements to individuals.

This means that Wednesday, March 2, 2023 is the deadline to furnish individuals with 2022 Forms 1095-C and 1095-B. This extension is automatic; employers or other reporting entities are not required to file a request with the IRS, or to demonstrate reasonable cause to justify the extension.

It should be noted that the final rule did not extend the deadline to file completed Forms 1095-C and 1095-B with the IRS. This due date remains March 31, 2023 (or February 28, 2023 for paper filing if filing fewer than 250 forms).

While the IRS has provided the automatic extension of time to furnish these statements, it should be noted that if an ALE is operating in a state with an individual mandate, the timing to furnish proof of coverage to covered residents may be different.

As always, don’t hesitate to contact your Total Benefit Solutions health insurance specialists with questions or concerns today at (215)355-2121.