ACA Changes to Note for 2016

Delay on Excise Tax “Cadillac Tax”

On December 18, 2015, President Obama signed the Omnibus spending bill, which provides a provision to delay the Affordable Care Act (ACA) Excise Tax, “Cadillac Tax” from 2018 until 2020. The bill also makes the tax a deductible expense for employers. Although the delay gives relief to plan sponsors, they should continue to review and make necessary plan changes for the tax in 2020.

ACA Reporting: 2015 Forms Due Dates Extended

On December 28, 2015, the Internal Revenue Service issued Notice 2016-4 (the “Notice”), which extends the due dates for furnishing and filing the new ACA reporting forms for the 2015 calendar year.

The extended deadline for furnishing the 2015 Forms:

• Form 1095-C and Form 1095-B to individuals is March 31, 2016 (it was February 1, 2016).
• Forms 1094-C and 1095-C with the IRS is June 30, 2016 if filed electronically (it was March 31, 2016). If filing in paper form, the new deadline is May 31, 2016 (it was February 29, 2016).
• Forms 1094-B and 1095-B with the IRS is June 30, 2016 if filed electronically (it was March 31, 2016). If filing in paper form, the new deadline is May 31, 2016 (it was February 29, 2016).

Note: Electronic filing to the IRS for Forms 1094-C and 1095-C is required, except for employers with fewer than 250 returns during a calendar year.

Despite the due date extension, an employer or coverage provider is permitted to provide the applicable Forms to individuals or the IRS on or before the original due date. The IRS is encouraging employers and coverage providers to “furnish statements and file the information returns as soon as they are ready.”

If you have a contract with a third-party vendor assisting with ACA reporting, it’s recommended that you have a discussion with the provider about the deadline extensions to determine whether the Forms will be filed using the original or extended deadlines.

Please contact your BPAS Healthcare Consulting representative if you have any questions on this notice or any other ACA reporting requirements.