The Internal Revenue Service (IRS) finally released the Affordable Care Act (ACA) reporting forms and related instructions for the 2019 plan year with no material changes. Nonmaterial changes include (non- exhaustive):
• “Instructions for Recipient” included with Form 1094/0195-B have been revised reflecting the individual shared responsibility penalty reduced to zero.
• Instructions for both the B and C forms have new “What’s New” section summarizing the recent reporting delay with related good faith relief. See the Leavitt article for complete details.
The ACA Information Returns (AIR) Operational Status webpage now indicates that electronic filing will open January 15, 2020.
With the delay recently issued, employers / plan sponsors have until March 2, 2020 to furnish forms to participants (delayed from January 31) and, unchanged, until February 28 or March 31, 2020, if filing electronically, to submit forms to the IRS. It is recommended to start the work required for reporting by now, with submission of relevant data to your reporting vendors or team by January. The availability of an additional month for furnishing forms to participants should provide plenty of time but no extra extension is now available for furnishing to individuals as a result. An automatic 30-day extension still applies to the deadline for submitting forms to the IRS if filed before the deadline.
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