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Affordable Care Act (ACA)

December 14, 2016
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Large employers and employers with self-funded insurance plans still have a requirement to file their 2016 1094/1095 forms in a timely manner. The non-deductible penalties for not filing these forms range from $260 to $520 per form.
On November 18, 2016, the IRS announced via IRS Notice 2016-70 that it has issued transition relief for filing 2016 ACA Forms 1095-B and 1095-C, which extends the due date from January 31, 2017, to March 2, 2017.  Filers must continue to file Forms 1094-B, 1095-B, 1094-C and 1095-C to the IRS by February 28, 2017, if filing paper and March 31, 2017, if e-filing.
Notice 2016-70 also extends the transition relief for sections 6721 and 6722 penalties if a good faith effort is made in preparing the forms.  This penalty relief is the same as it was for the 2015 forms.  The penalty relief does not apply to a failure to file the forms in a timely manner.  This notice applies only to 2016 forms and not to any future years.  The IRS does not intend to extend this relief for the 2017 ACA filing period.
For more information, contact Michael Criscione at