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Reminder: No Extensions on ACA Reporting Deadlines for 2021

ACA reporting deadlines appear to have returned to normal for 2021. Last year at this time, the IRS issued Notice 2020-76, announcing it was extending the January 31 deadline to provide individuals with a copy of Form 1095-B and/or 1095-C by 30 days. This year, no extension has been announced, nor is one expected.

That means the 2021 deadline for providing individuals with Forms 1095-B or 1095-C is January 31, 2022. The deadlines for filing Forms 1094-B and 1095-B, or Forms 1094-C and 1095-C, to the IRS also remain unchanged. For paper filers, the deadline is February 28, 2022. Electronic filers have until March 31, 2022.

Under current rules, employers that submit 250 or more of the same form must file electronically. However, a new IRS proposed rule could significantly impact the way small employers submit their tax filings. If finalized, nearly all employers would be required to electronically file various tax forms, including Forms 1094-C and 1095-C. The proposed rule would lower that threshold to 100 forms for 2022 and only ten forms for 2023 and beyond. This rule would also require employers to aggregate all the forms they are submitting.

Who provides these forms?

As a reminder, all applicable large employers (ALE) must file Forms 1094-C and 1095-C with the IRS and furnish a copy of the 1095-C to all full-time employees. The insurance carrier for a fully insured plan must complete Forms 1094-B and 1095-B. Some employers must complete and distribute the 1095-B if they are a non-ALE self-insured plan.

Companies that are part of a controlled group are an ALE member in the aggregate ALE group. Each ALE member must complete the Form 1094-C and 1095-C. If employers have only one Form 1094-C, that Form must report aggregate employer-level data for the ALE member and be the Authoritative Transmittal. If multiple Forms 1094-C are being filed for an ALE member so that all full-time employees’ Forms 1095-C are not attached to a single Form 1094-C transmittal, one of the Forms 1094-C must report aggregate employer level data for the ALE member and be the Authoritative Transmittal.

Review your procedures now so you can meet these critical deadlines. If you have questions, contact your OneDigital consultant.


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