The New Deadline To Furnish Form 1095-C To Employees Is March 2, 2023

CATEGORY: Client Update for Public Agencies, Private Education Matters, Public Education Matters
CLIENT TYPE: Private Education, Public Education, Public Employers
DATE: Feb 07, 2023

The IRS finalized regulations extending the deadline for employers to furnish Form 1095-C to employees.  (See 87 Fed. Reg. 76569, December 15, 2022.)  Beginning January 1, 2023, the deadline is permanently extended 30 days from January 31 to March 2 of the year following the calendar year to which the statement relates.  For minimum essential coverage provided in 2022, the deadline to furnish statements to employees is March 2, 2023.  Since the extension is automatic, the regulations removed the option for employers to submit a written request for an extension for a good cause and the IRS’s discretion to prescribe any other automatic extension.

Applicable large employers are required to file information returns and furnish written statements with respect to the health insurance if any, that the employer offers to full-time employees.  The IRS uses the information returns to administer the employer-shared responsibility provisions of the Affordable Care Act.  The IRS has generally designated Form 1095-C to meet the requirement that applicable large employers furnish individual employees with a written statement identifying the offer of employer-sponsored minimum essential coverage.

While the due date to furnish Forms 1095-C has been permanently extended to March 2, applicable large employers are still required to file Forms 1094-C and 1095-C with the IRS on or before February 28th, if filing on paper, or March 31st, if filing electronically.  Notably, employers filing 250 or more returns are required to file electronically.  Employers that would like an automatic 30-day extension to file Forms 1094-C and 1095-C must submit Form 8809 on or before the due date of the returns.

Employers who fail to furnish or file statements by the deadlines are subject to penalties unless the failure is due to reasonable cause and not to willful neglect.

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