Health Care Reform Advisory | 2015 ACA Reporting Deadlines Extended


On December 28, 2015, the IRS extended the 2015 deadlines for employers and insurers to complete reporting requirements under the Affordable Care Act (ACA) with the issuance of IRS Notice 2016-4. The notice provides a 60-day extension for filing Form 1095 and a three month extension for filing Form 1094 with the IRS.

  • Form 1095 (B or C) for 2015 to employees (and other covered individuals): Deadline extended from February 1, 2016 to March 31, 2016
  • Form 1094-B and Form 1094-C for 2015 to the IRS by health coverage providers and employers NOT filing electronically: Deadline extended from February 29, 2016 to May 31, 2016
  • Form 1094-B and Form 1094-C for 2015 to the IRS by health coverage providers and employers filing electronically: Deadline extended from March 31, 2016 to June 30, 2016


Applicable Large Employers (ALEs) are required to report whether Minimum Value, affordable coverage was offered to any full-time employees (full-time for at least one month during the year). ALEs are employers with 50 or more full-time employees (including full-time equivalents); and therefore, subject to the ACA coverage mandate and penalty exposure.

IRS Notice 2016-4 specifically mentions that many employers and vendors are not yet prepared to comply by the initially issued deadlines. The Notice states that no further extensions will be granted on an employer-by-employer basis and penalties will apply for employers failing to file by the new deadline. 


IRS Notice 2016-4 clarifies that individuals do NOT need to provide the IRS with a copy of Form 1095 when filing individual tax returns, but some individuals may need the information on Form 1095 for purposes of determining premium tax credit (subsidy) eligibility or whether covered by Minimum Essential Coverage.

For 2015 reporting, individuals who do not receive a Form 1095 prior to filing their tax returns may rely on other sources of information for these purposes and will not be required to file an amended return if / when a Form 1095 containing different information is delivered.


The extensions are welcome news. However, many employers may still struggle to meet the newly extended deadlines, so it is important to continue preparation as the IRS is clear that penalties ($250 per form) will apply.

As clarifying regulations and implementation modifications are issued, Oswald will continue to provide updated information in implementing the strategic, financial and administrative challenges of the ACA. Please contact your Oswald representative with specific questions.

Oswald Companies | Health Care Reform Implementation Review

Danielle Jarvis |; 216.649.7384
Luke Clark |; 216.367.8758
Marianne Ernst |; 216.367.4917

Disclaimer: Materials are solely for informational purposes as an educational resource. Please contact counsel to obtain advice with respect to any specific issue.