ACA Compliance

IRS Extends Form 1095 Distribution Deadline for 2019 ACA Reporting

The IRS announced it has extended the deadline for employers to provide Forms 1095 to individuals from January 31, 2020, to March 2, 2020, regarding the Affordable Care Act (ACA) for 2019, per Notice 2019-63
This extension applies only to Form 1095 distribution. The dates for employers to file information returns (Form 1094) with the IRS, however, have not been extended. The dates for those filings remain the same, as follows:

Form 1094 Deadline
Paper Filing
Only an option for employers with less than 250 individual statements
February 28, 2020
Electronic Filing
Mandatory for employers with 250 or more individual statements
March 31, 2020

IRS Extends ‘Good Faith’ Relief

The IRS also announced it is extending “good faith” relief for the 2019 tax year filing. Good faith has been provided in previous years to employees for reporting incorrect or incomplete information regarding their ACA compliance. This relief applies to missing and inaccurate taxpayer identification numbers and dates of birth, as well as other information required on Forms 1094 and 1095.
It is important to note this relief does not apply to failure to file or filing late, and employers are subject to a penalty for failing to timely file an information return.
These mandated ACA reporting and compliance requirements apply to all employers with 50 or more full-time or full-time equivalent employees and all self-insured employers of any size.

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