Employee Benefits Compliance, Reporting & Disclosure, Reporting Requirements

2020 ACA Forms 1094/95 Reporting Deadline Extended

The Internal Revenue Service (IRS) released Notice 2020-76 announcing relief for the Affordable Care Act’s (ACA) Forms 1094/95 information reporting returns for the 2020 tax year. This relief, in the form of a delayed deadline, largely follows the same relief offered in recent prior years. See the Leavitt Group article on the 2019 reporting delay.

Furnishing Statement to Individuals

An automatic extension of 30-days is provided. As a result, the permissive 30-day extension is not available for the 2020 reporting year.

Original Deadline New Deadline
January 31, 2021 March 2, 2021

IRS Reporting

IRS reporting is still due its original dates, with the exception of paper filing due on a Monday due to the deadline falling on a Sunday.

Original Deadline New Deadline
February 28, 2021 (paper) March 1, 2021 (paper)
March 31, 2021 (electronic) March 31, 2021 (electronic)

Additional Relief

Good faith relief from penalty upon a showing that the employer made good-faith efforts to comply with the reporting requirements. This relief only applies to missing and inaccurate taxpayer identification numbers and dates of birth, and other required information. Such relief is not available for missing filing deadlines or filing altogether.

Evidence of good faith efforts:

  • Evidence of data collection.
  • Transmission to a third-party service provider.
  • Testing IRS transmission.

The 2020 year will be the last year good faith compliance relief will be offered.

Form 1095-B relief from penalty for furnishing individuals this form was computed to zero following the repeal of the individual mandate penalty. Since there is no longer a penalty, there is relief from the penalty to provide the B form. This latest relief only provides temporary relief from penalty for failing to furnish this form where meeting two conditions:

  • Post a notice prominently on website of where to receive a copy of the 2020 Form 1095-B, upon request. Include: contact email, physical address and telephone number.
  • Furnish the 2020 Form 1094-B upon request within 30 days.

This relief does not extend to the Form 1095-C for full-time employees of Applicable Large Employers enrolled in self/level-funded plans. With the automatic extension option, there are no other extensions available.

Other Reporting Penalties

This notice also provides relief from the 6721 and 6722 penalties associated with submitting late filings and submitting incorrect returns during the extension.

Conclusion

Employers should ensure they are tracking and collecting needed coverage data already to ensure submission of required reporting by the due date. Even with the extension of the due date for furnishing forms to individuals, the reporting deadline for IRS submission is unchanged. Be sure to report to the IRS on time. It is far better to submit with errors or missing information than late. Report on time…even if incomplete. Remember to work with a trusted service provider. Consult with the Leavitt Group for our preferred partnerships with valued ACA reporting service providers.

 

This information is an educational summary not intended to serve as legal or financial advice. Consult your own legal or tax professional to ensure compliance with all law applicable to your specific circumstances. 

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