Formerly S.S. Nesbitt Rebranding FAQ

Per Notice 2019-63, the IRS extends the deadline for certain 2019 health information reporting from January 31, 2020 to March 2, 2020. This extension applies to Forms 1095-C and 1095-B provided to individuals.

Due to this extension, the IRS will not grant additional time for reporting entities to furnish the returns to individuals, which would otherwise be available for a showing of good cause or by submitting Form 8809.

Deadlines for forms due to the IRS have not been extended. They remain February 28, 2020 for paper copy and March 31, 2020 if filed electronically.

Additionally, in response to the reduction of the ACA’s Individual Mandate penalty to $0 in 2019, the IRS provides penalty relief for the following reporting failures:

  • Failure to furnish a 2019 Form 1095-B to individuals, if the reporting entity complies with the following requirements:
    (1) Post a notice on its website to let individuals know they can request a copy of their 2019 Form 1095-B and include specific contact information; and
    (2) Furnish the Form to the individual within 30 days of receipt of the request.
  •  Failure to furnish a 2019 Form 1095-C to an employee enrolled in the employer’s self-insured health plan if the employee is not full-time for any month in 2019.

Lastly, the IRS extends penalty relief for incorrect or incomplete information on the forms, if a reporting entity can demonstrate good-faith efforts to comply with the Sections 6055 and 6056 requirements.

For details, please see the Notice.

On a separate note, please be aware that certain states, including New Jersey, Massachusetts and the District of Columbia, have imposed a health plan reporting requirement on employers. If you have employees in those areas, be sure to discuss these requirements with your reporting vendor.