The IRS has issued Notice 2020-76 extending the due date for the 2020 1095-B and 1095-C forms to be sent to employees from January 31, 2021 until March 2, 2021.
However, the Notice also confirms that the due date for filing those same 1095 Forms with the IRS remains the same: February 28, 2021 if filing paper copies or March 31,2021 if filing electronically. the notice also extends the good faith transition relief for ACA Reporting, ut in a limited way, noting that 2021 is the last year this good faith relief will be offered.
A BenefitScape chart describing the due dates and relief is available for download.
What does this mean for you?
The IRS is providing all filers with an extension for distributing Forms 1095-B/C to their employees. Notice 2020-76 extends the forms-issuing deadline from January 31st, 2021 to March 2th, 2021, giving employers and if applicable, insurers, an additional month to furnish their Forms 1095-B/C. This extension applies only to ACA Regulations 6055 and 6066 for Tax Year 2020 and does not require the submission of any request or other documentation to the IRS.
Given this generous automatic extension, the previous provision allowing employers to request a 30-day extension to furnish Form 1095-B/C will not apply to the newly extended due date. It is important to note that while the IRS is providing all employers and other coverage providers an extension, they recommend and encourage filers to furnish their Tax Year 2020 Forms 1095-B/C Forms as soon as they are able to.
Good Faith Transition Relief Extensionut will be available for TY2020, but sunset and no longer available
Similar to Tax Year 2019, the IRS is extending their Good Faith Transition Relief from penalties under sections 6721 and 6722 to all reporting entitites can show that they have made good-faith efforts to comply with ACA information-reporting requirements for incorrect or incomplete information reporting on Forms 1095-B/C. No relief will be provided to filers that do not make a good-faith effort, meaning, reasonable efforts the employer made to prepare for reporting, such as gathering and transmitting accurate data, to comply with ACA reporting regulations.
This good faith relief only applies to the information in the forms, not the deadlines for providing or filing the forms. Furthur, no relief will be provided if the deadlines are not observed.
How We Can Help
Like the IRS, we recommend that you get started today on your ACA Reporting and Compliance responsibilities. Compiling and transforming data and furnishing Forms 1095-B/C is a complex process involving significant time and resources. Our team can support you in completing your ACA responsibilities and avoiding steep penalties by providing accurate and timely results. Get started today by calling us at (508) 655-3307, or email Kim at kim.phillips@benefitscape.com
