09 December 2021 State ACA furnishing deadlines looming for employers in states that have not followed IRS extension Despite the IRS's recent extension of the federal deadline for furnishing Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, to employees, some states with ACA reporting requirements have not extended their deadlines for furnishing these forms. While New Jersey and the District of Columbia have extended their deadlines, the deadline for furnishing Forms 1095-C remains January 31, 2022, for some states with ACA reporting requirements. The IRS extended the furnishing deadline to March 2, 2022, through proposed regulations (REG-109128-21) that would permanently extend the Affordable Care Act (ACA) reporting deadline for applicable large employers to furnish Form 1095-C to employees to 30 days after January 31. Taxpayers may rely on these proposed regulations for calendar years beginning after December 31, 2020 (see Tax Alert 2021-2165). The District of Columbia, New Jersey, Vermont, California and Rhode Island have enacted some form of an individual mandate. Each jurisdiction leverages the federal Form 1095-C for purposes of administering its individual mandate requirement. Massachusetts, which has had an individual mandate since 2006, uses its own reporting forms. The following chart shows the deadlines for the IRS and all states with an individual mandate as of December 8, 2021. The furnishment date is the date Form 1095-C needs to be postmarked/mailed to employees. The employer penalty may be assessed if Forms 1095-C are not mailed to employees by the deadline. The filing date is the date Form 1094-C and 1095-C must be submitted to the state filing agency. The employer penalty may be assessed if Forms 1094-C and 1095-C are not filed with the state filing agency by the deadline.
While the IRS has extended the deadline to furnish Forms 1095-C to individuals, some states still have a January 31 deadline. Employers producing these forms for individuals in states with the January 31 deadline should make sure the forms are post-marked by the correct date.
Document ID: 2021-2216 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||