Employer Mandate, Health Care Reform, Penalties, Reporting Requirements

2018 1095 Deadline Extended from Jan. 31 to March 4


  • The IRS just announced a 30-day extension to the deadline for providing 2018 Forms 1095-C and 1095-B to individuals. The deadline is now March 4, 2019, instead of January 31, 2019.
  • The IRS did NOT extend the deadlines for filing 2018 Forms 1094-C and 1094-B with the IRS. (see below for these dates)
  • The IRS also extended the “good faith” transition relief from penalties (generally $270 per return) for incorrect or incomplete information on the ACA reporting forms IF they are timely furnished and filed.
  • These are the same extensions the IRS granted for 2017 and 2016 ACA reporting.
  • Today’s IRS Notice is Notice 2018-94


  • January 31, 2019 March 4, 2019: 1095-C or 1095-B forms furnished (delivered) to employees
    • IRS Notice also states that the 30 Day Automatic Extension for which employers can normally apply does NOT apply to the extended due date.
  • February 28, 2019:  Paper filings with IRS, deadline to mail 1094-C or -B forms (plus copies of 1095-C or –B forms).
  • April 1, 2019: Electronic  filings with IRS, deadline to file 1094-C or -B forms (plus copies of 1095-C or –B forms) —  eFiling with IRS is through the AIR system
  • If filing fewer than 250 1095-C forms, eFiling is optional
  • If filing 250 or more 1095-C forms, eFiling is mandatory


  • Filing penalties may be imposed by the IRS for two different reasons: 1) Late filings, and            2) inaccurate or incomplete filings.
  • The IRS is not offering relief from late filing penalties; instead, as noted above, it is extending the 1095 deadline by 30 days.  (No extension of 1094 filing deadline.)
  • The good-faith transition relief from penalties means that plans sponsors (and carriers) can apply for relief from penalties if they timely filed inaccurate or incomplete 2018 forms, and any mistakes were made in good faith. Examples of inaccurate or incomplete filings include those with incorrect or missing SSNs and DOBs.
  • This makes it even more important that employers furnish and file the 1095s and 1094s by the applicable deadlines, in case they later need to take advantage of the transition relief from inaccuracy penalties.

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