Affordable Care Act, Good Faith

IRS Permanently Extends Deadlines for ACA Reports to Individuals

Proskauer - Employee Benefits & Executive... on 1/4/2023

On December 15, 2022, the Internal Revenue Service (“IRS”) published final regulations that make permanent certain relief and changes relating to the Affordable Care Act (“ACA”) reporting requirements. Specifically, the final...more

Benefits Monthly Minute UPDATE: RxDC Reporting Relief

Keating Muething & Klekamp PLL on 12/28/2022

On December 23, 2022, FAQs were released outlining late-breaking RxDC Reporting Relief. Of note - 1. For the 2020 and 2021 data submissions that are due by December 27, 2022, the Departments will not take enforcement...more

No More Mister Nice Guy…No More “Good-Faith” Relief for ACA Reporting Requirements

Holland & Hart - The Benefits Dial on 1/13/2022

The good news is that the deadline to furnish individuals with the Form 1095-C or Form 1095-B reporting health care coverage in 2021 has been extended to March 2, 2022. The bad news is that the days of good-faith relief are...more

Elimination of Good Faith Relief for ACA Reporting

Verrill on 1/11/2022

On November 22, 2021, the Internal Revenue Service (IRS) published proposed regulations that codify, among other things, an automatic extension of the deadline for furnishing IRS Forms 1095-C to employees. IRS Forms 1095-C...more

IRS Proposes Regulations on ACA Reporting: Good News and Bad News for Employers

Bradley Arant Boult Cummings LLP on 11/24/2021

The Internal Revenue Service (IRS) has published proposed regulations that, if finalized, will ease some of the requirements imposed on employers reporting offers of minimum essential health coverage, including a permanent...more

Federal Government Announces Enforcement Discretion, Deferral For Certain Price Disclosures And Future Rulemakings

Sheppard Mullin Richter & Hampton LLP on 8/25/2021

Health plans and issuers racing to implement overlapping price transparency and disclosure requirements in response to the Transparency in Coverage final rule (TiC Final Rule) and the Consolidated Appropriations Act, 2021...more

IRS announces relief for certain Form 1094/1095 reporting requirements

McAfee & Taft on 10/19/2020

In a similar move as in previous years, the IRS has issued relief from certain Form 1094-C and 1095-C reporting requirements under the Affordable Care Act relating to employee health plans, as well as relief from certain...more

IRS Extends Deadline for Certain ACA Reporting Requirements

Faegre Drinker Biddle & Reath LLP on 10/14/2020

In Notice 2020-76 (Notice), the IRS extended the deadline from January 31, 2021, to March 2, 2021, for furnishing Forms 1095-B and 1095-C to individuals for reporting year 2020. Note that the Notice does not extend the...more

Ho, Ho, Ho, ACA Reporting Relief Five Years in a Row

Burr & Forman on 12/16/2019

Since 2015, employers and health insurers have been required to report health plan coverage information to the IRS and to individuals. Why? The information is necessary in order for the IRS to administer certain portions of...more

An IRS Holiday Gift: 2019 Affordable Care Act Reporting Relief

Ogletree, Deakins, Nash, Smoak & Stewart,... on 12/11/2019

The Internal Revenue Service (IRS) issued Notice 2019-63 on December 2, 2019 providing some relief from Affordable Care Act (ACA) reporting requirements. The notice provides relief consistent with that provided in the past...more

A Post-Thanksgiving Treat: IRS Extends Certain ACA Reporting Deadlines and Transition Relief

Snell & Wilmer on 12/6/2019

The IRS provided welcome news to employers preparing to comply with the Affordable Care Act’s (“ACA”) information reporting requirements in early 2020 for the 2019 calendar year. In particular, Notice 2019-63 (the “Notice”)...more

Thank You IRS - Extensions for This Year’s ACA Tax Reporting

Foley & Lardner LLP on 1/11/2018

The “Bottom Line” - Employers will have until March 2, 2018 to furnish Form 1095-C (“Employer-Provided Health Insurance Offer and Coverage”) to employees.,,...more

IRS Once Again Extends Distribution (Not Filing) Deadline for ACA Reporting and Continues Good Faith Standard

Proskauer - Employee Benefits & Executive... on 1/3/2018

Following the old “better late than never” axiom, the IRS recently announced (see Notice 2018-06) that once again it would be extending the distribution (but not filing) deadline for the Affordable Care Act (ACA) reporting...more

CMS Aims to Stabilize Exchanges but Does Not Address Issuers’ Biggest Questions

McDermott Will & Emery on 4/26/2017

CMS recently released a final rule with the goal of stabilizing Exchange markets for 2018. The agency also issued several significant guidance documents where CMS extended the deadlines for 2018 rate and Exchange qualified...more

IRS Grants Extension of ACA Information Reporting Deadline and Provides Good Faith Standards for 2016 Information Reports

Franczek P.C. on 12/1/2016

The IRS recently issued Notice 2016-70, which extends certain 2017 deadlines for employer information reporting under the Affordable Care Act (ACA) on health coverage offered to individuals during the 2016 calendar year. The...more

Extension for Good-Faith Reporting and 2016 Forms 1095-C and 1094-C

McDermott Will & Emery on 11/22/2016

On November 18, 2016, the Internal Revenue Service issued Notice 2016-70, extending both the due date for furnishing individuals with Forms 1095-C and 1095-B, in addition to certain good-faith transition relief to the 2016...more

Late Or Incorrect Forms 1095-C: The IRS Provides Relief, But Only For Employers Acting In Good Faith To Comply Or Who Missed The...

Snell & Wilmer on 4/15/2016

Many employers struggled to furnish correct Forms 1095-C to employees by the March 31, 2016 deadline. Section 6721(a)(2) of the Internal Revenue Code provides penalties for failure to furnish Forms 1095-C to individuals by...more

ACA Reporting Update – The Final Stretch

Proskauer - Employee Benefits & Executive... on 3/3/2016

After months of preparation and multiple iterations of (sometimes conflicting) IRS guidance, health coverage providers and applicable large employers are nearing the end of the 2015 reporting season under the Affordable Care...more

Affordable Care Act Reporting is Here (But May be a Little Late…)

Foley & Lardner LLP on 3/3/2016

The Affordable Care Act requires “applicable large employers” (generally, employers with 50 or more full-time employees and full-time employee equivalents) to provide individual statements to their full-time employees and to...more

The ERISA Litigation Newsletter - December 2015

Proskauer Rose LLP on 1/4/2016

Editor's Overview - In this month's newsletter, we focus on the recent wave of guidance and case law related to the Affordable Care Act. We also discuss IRS Notice 2015-86, which provides guidance on the application of...more

IRS Extends Deadlines for Affordable Care Act Reporting

Proskauer - Employee Benefits & Executive... on 12/29/2015

On December 28, 2015, the IRS released Notice 2016-4, which extended the distribution and filing deadlines for the Affordable Care Act (ACA) reporting requirements set forth in Sections 6055 and 6056 of the Internal Revenue...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 2 of 24): Yikes! The Costs of Failing to Comply...

Mintz - Employment, Labor & Benefits... on 7/27/2015

The Affordable Care Act (ACA) imposes information reporting rules on providers of minimum essential coverage, e.g., insurance carriers and self-funded plans, and on applicable large employers, i.e., those employers that are...more

Patient Protection and Affordable Care Act (PPACA) › Good Faith