IRS Grants 2019 ACA Reporting Relief
On December 2nd the Internal Revenue Service (IRS) released Notice 2019-63, which provides three sets of relief for the upcoming Affordable Care Act (ACA) reporting year. This an early Christmas gift for employers and health insurers that are subjec to ACA reporting. Two types of relief are very familiar if you have any experience with ACA reporting. The third type of relief is new to this reporting cycle and only applies to health insurers that are required to provide the B Series forms, so it is somewhat irrelevant to employers in their compliance journey.
Employers will be happy to hear that they have a 30-day extension for the employee fulfillment portion of compliance this year. That means that the original deadline of January 31st is now pushed back to March 2nd, which is always helpful as employers are swamped with tax and other reporting requirements this time of year.
The second relief that employers receive is the extension of the “good faith effort” relief. This relief applies to missing and inaccurate taxpayer identification numbers and dates of birth, as well as other information required on the 1095-C. Reporting entities must make a good-faith effort to comply with the regulations in order to receive this relief. Remember that employers must file and file on time if they want to rely on this relief. The guidance makes it clear what the IRS is looking for in order to receive this relief.
“In determining good faith, the Service will take into account whether an employer or other coverage provider made reasonable efforts to prepare for reporting the required information to the Service and furnishing it to employees and covered individuals, such as gathering and transmitting the necessary data to an agent to prepare the data for submission to the Service or testing its ability to transmit information to the Service. Reporting entities that fail to file an information return or furnish a statement by the extended due dates, except as otherwise provided in this notice, are not eligible for relief.”
The final relief applies to health insurers that provide the B Series form. The IRS is not requiring these entities to provide a 1095-B to individuals, so long as the following two conditions are met:
- First, the reporting entity posts a notice prominently on its website stating that responsible individuals may receive a copy of their 2019 Form 1095-B upon request, accompanied by an email address and a physical address to which a request may be sent, as well as a telephone number that responsible individuals can use to contact the reporting entity with any questions.
- Second, 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.
This relief is being granted do to the fact that the penalties associated with the Individual Mandate of the ACA have been zeroed out for 2019, therefore individuals do not need the B Series form to complete their individual tax forms. Again, this really has no impact on employers during this upcoming reporting season.
Overall, this relief is good news for employers, and even better for entities that are required to provide the B Series forms to individuals. Employers should be prepared for the upcoming filing season, and make sure they do everything in their power to stay compliant and avoid potentially devastating penalties!
Tags: ACA Reporting