Under the original provisions of the ACA, the due date for providing Forms 1095 to employees was February 1, 2016. Employers had until February 29, 2016 to file Forms 1094 & 1095 with the IRS (if submitting these forms electronically, the deadline was March 31, 2016). However, on December 28, 2015, the Internal Revenue Service issued Notice 2016-4 which extended the due dates for furnishing and filing Affordable Care Act reporting forms for the 2015 tax year.

The new deadline for furnishing 2015 Forms 1095-B (Health Coverage) and 1095-C (Employer-Provided Health Insurance Offer and Coverage) to employees will now be March 31, 2016. The deadline for filing copies of the above-referenced forms with the IRS, along with Transmittal Forms 1094-B and 1094-C, was extended to May 31, 2016. Forms submitted electronically are now due by June 30, 2016.

Despite the extensions of time, the IRS is encouraging employers and coverage providers to furnish the statements and file the information returns as soon as possible.

For additional information please see Update to 2016 Accountants’ Memorandum




We highly recommend you confer with your Miller Kaplan advisor to understand your specific situation and how this impacts you.