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IRS Grants Minimum Extension for ACA Information Reporting

January 19, 2016

The Internal Revenue Service (IRS) issued Notice 2016-4, which extends the due dates for filing the 2015 information reporting requirements electronically to June 30, 2016 under the Affordable Care Act (ACA) for forms 1094 and 1095.

NAFOA is disappointed that the IRS did not take into consideration the very substantial tribal government and tribal organizations' concerns from the 12/01/15 consultation call to grant an extension of transition relief to January 2017. Considerable planning and execution across tribal departments will be required to complete the tax information returns, which entails reporting monthly on whom the coverage was offered to (employee, spouse, dependent), and the employee share of lowest cost of coverage.

Previous Due Date

New Due Date

Forms 1095-B and 1095-C due to individuals by
Feb 1, 2016

 March 31, 2016

Forms 1094-B, 1094-C, 1095-B, and 1095-C due if filing on paper by
Feb 29, 2016

 May 31, 2016

Forms 1094-B, 1094-C, 1095-B, and 1095-C due if filing electronically by
March 31, 2016

 June 30, 2016

The Notice also states that employers that do not comply with the new extended due dates will remain subject to penalties for failures to file on time. The Notice encourages employers that do not meet the deadlines to nonetheless file because the IRS will take into account the extent to which employers are taking steps to ensure they are in compliance with the financial reporting requirements for 2016.

NAFOA will continue to work with the Department of Treasury to provide tribal governments with additional training and time to comply.

For questions or comments, please contact Jennifer Parisien at or (202) 558-8040. 

NOTE - Future Filing Dates:

Please note, the extensions apply only to 2015 returns and information statements and do not apply to future years. The 2016 forms will be due by Feb 28, 2017 if filing by paper or March 31, 2017 if filing electronically.