The Patient Protection and Affordable Care Act ("ACA") imposes reporting requirements on providers of minimum essential coverage (including insurers and employers that self-insure health benefits) about the coverage provided. In addition, large employers (generally those with 50 or more full-time and full-time equivalent employees in the prior year) must report about the health coverage offered by the employer to its full-time employees.

The reporting requirements require employers to provide certain information reports to full-time employees and others who are enrolled in coverage (Form 1095-B and Form 1095-C). Employers must also provide certain reports to the Internal Revenue Service ("IRS") (Form 1094-B and Form 1094-C). The IRS will use the information to determine whether an employer has complied with the ACA requirement to offer affordable, minimum value health coverage to full-time employees and their dependent children or whether the employer will owe a penalty. The IRS will also use the information to determine individual compliance with the requirement that most individuals maintain minimum essential health coverage or pay a penalty, and to determine individual eligibility for a premium tax credit for coverage purchased through a health insurance marketplace.

The due date for providing information reports to full-time employees has been extended; however, the due date for the IRS reports has not been extended.  The due dates for 2016 reports are as follows:

• The due date for providing the reports to full-time employees and others enrolled in coverage (IRS Forms 1095-B and 1095-C) has been extended from January 31, 2017 to March 2, 2017.
• The due date for filing returns with the IRS (IRS Forms 1094-B, 1095-B, 1094-C and 1095-C) remains at February 28, 2017 (or March 31, 2017 if filing electronically).

The filing extension may affect some individuals if they do not receive the Form 1095-B or 1095-C before they file their income tax returns. As a result, for 2016, individuals may rely on other information received from employers or coverage providers for purposes of filing their returns, including determining eligibility for the premium tax credit and whether they had minimum essential coverage.