IRS Provides Transition Relief For 2019 ACA Reporting

On December 2, 2019, the Internal Revenue Service (IRS) issued Notice 2019-63 to:

  • Extend the due date for furnishing forms under Sections 6055 and 6056 for 2019 from January 31, 2020 to March 2, 2020;
  • Extend good-faith transition relief from penalties related to 2019 information reporting under Sections 6055 and 6056; and
  • Provide additional penalty relief related to furnishing 2019 forms to individuals under Section 6055.

The due date for filing forms with the IRS remains February 28, 2020 and March 31, 2020 if filing electronically.

Extended Furnishing Deadline

The IRS determined that some employers, insurers and other providers of minimum essential coverage (MEC) need additional time to gather and analyze information. This explains why the notice provides an additional 31 days for furnishing the 2019 Form 1095-B and Form 1095-C.

Employers and other coverage providers are still encouraged by the IRS to furnish 2019 statements to individuals as soon as they are able.

Impact on Filing Deadline

The IRS has determined that there is no need for additional time for employers, insurers and other providers of MEC to file 2019 forms such as Forms 1094-B, 1095-B, 1094-C or 1095-C with the IRS therefore, the due date will remain the same.

  • Deadline: February 28, 2020 if filing on paper.
  • Deadline: March 31, 2020 if filing electronically.

Extension of Good-Faith Transition Relief from Penalties for 2019

The notice extends transition relief from penalties for providing incorrect or incomplete information to reporting entities that can show that they have made good-faith efforts to comply with Section 6055 and Section 6056 reporting requirements for 2019. This applies to missing and inaccurate taxpayer identification numbers, dates of birth, and other information required on the return or statements.

If you are a reporting entity that does not make a good-faith effort to comply with regulations; or fail to file an information return or furnish a statement by the extended due dates (except as otherwise provided in Notice 2019-63), no relief will be provided.

Penalty Relief Related to Furnishing 2019 Forms under Section 6055 for 2019

Due to the individual mandate penalty being reduced to zero in 2019, an individual does not need the information on Form 1095-B in order to calculate his or her federal tax liability or file a federal income tax return.

As a result, Notice 2019-63 provides relief from the penalty for failing to furnish a statement to individuals as required under Section 6055 in certain cases. The IRS will not assess a penalty under Section 6722 against reporting entities for failing to furnish a Form 1095-B to responsible individuals, if:

  • The reporting entity prominently posts a notice on its website stating that responsible individuals may receive a copy of their 2019 Form 1095-B upon request, accompanied by an email address, a physical address, and a telephone number for individuals to reach out to with questions.
  • The reporting entity furnishes a 2019 Form 1095-B to any responsible individual upon request within 30 days of the date the request is received.

The 2019 section 6055 furnishing penalty relief does not affect the requirement or the deadline to file the 2019 Forms 1094-B, 1095-B, 1094-C or 1095-C, as applicable, with the IRS.

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