News & Resources

Health Care Reporting Forms: 30-Day Extension Of Distribution Deadline and Penalty Relief

30-Day Extension

Similar to prior years, the IRS has again announced that employers have more time to distribute 2019 health coverage information returns to employees. However, the deadline for filing these forms with the IRS has not changed.

Specifically, IRS Notice 2019-63 extends the due date for furnishing to individuals the 2019 Form 1095-B, Health Coverage, and the 2019 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, from January 31, 2020, to March 2, 2020. (This due date takes into account that 2020 is a leap year and that March 1, 2020 is a Sunday.) Similar to prior years, the IRS will not take requests for further extensions of this deadline.

Note, however, that Notice 2019-63 does not extend the due date for filing with the IRS 2019 Forms 1094-B, 1095-B, 1094-C, or 1095-C. That due date remains February 28, 2020 (leap year not recognized), if not filing electronically, or March 31, 2020, if filing electronically. Similar to prior years, filers may request an automatic 30-day extension of those filing deadlines.

Penalty Relief

New for this year, the IRS will waive penalties for failing to furnish certain forms when employers and insurers meet defined requirements. The individual mandate penalty was reduced to $0 beginning in 2019; therefore, an individual no longer needs the information on a Form 1095-B in order to compute or file a 2019 income tax return. (Those who are subject to individual mandate legislation in New Jersey and the District of Columbia must furnish and have no penalty relief.)

In particular, the IRS has stated that employers and insurers will not be assessed penalties for failure to furnish 2019 Forms 1095-B as long as they meet two conditions:
  1. The reporting entity must post a notice prominently on its website stating that individuals may receive a copy of the form on request, and
  2. The reporting entity much furnish the form within 30 days of receipt of that request.
Self-insured plans with part-time employees: Penalty relief for failing to furnish certain forms also applies to applicable large employers required to furnish Forms 1095-C to report enrollment in Part III (i.e., self- insured plans) to anyone who is not a full-time employee for any month in 2019. The furnishing relief does not extend to full-time employees.

Notice 2019-63 continues to extend transition relief from penalties under sections 6721 and 6722 to employers that can show that they have made a good-faith effort to comply with the reporting requirements for 2019 (both for furnishing to individuals and for filing with the IRS) for incorrect or incomplete information reported on the return or statement. 

Please contact your Sisterson representative with questions.