ACA Reporting Advisor

Welcome to MSEC’s weekly ACA FAQ on reporting. While details on how to complete IRS forms 1094 and 1095 (such as what codes to use on specific lines of the form) will not be covered, we will address general questions on reporting requirements. For detailed information on form completion, contact your broker, tax advisor, payroll company, or insurance carrier. If you have a general ACA reporting question, email it to aca@msec.org. The most commonly asked questions will be answered in this forum. In addition, the Health Care Reform Learning Zone, found on the MSEC website (msec.org), is a rich source of information about the Affordable Care Act (ACA).

Q:  Can I get a filing extension for Forms 1094-C and 1095-C?

Yes.  The process for obtaining an extension is different for returns filed with the IRS versus statements provided to employees.

Returns Filed with the IRS

An automatic extension of 30 days can be obtained by completing and filing Form 8809 (Application for Extension of Time to File Information Returns) on or before the due date of the returns. No explanation is required to receive the extension. As a reminder, the forms are due February 28 unless filing electronically. Electronic filings are due March 31.  Electronic filings are required of employers with 250 or more returns.

The form can be submitted hard copy to the mailing address listed in the instructions of Form 8809 or it can be sent through the FIRE System either as a fill-in form or an electronic file. Filers are encouraged to submit extensions using the online fill-in form.

Under certain hardship conditions, filers may apply for an additional 30-day extension.

For more information on Form 8809 see https://www.irs.gov/pub/irs-pdf/f8809.pdf.

Statements Provided to Individuals

An extension may be requested by sending a letter to the IRS at the mailing address listed in the Form 1094-C and 1095-C Instructions on or before the date on which the statements are due (January 31).  The letter must include:

  • filer name,
  • filer TIN,
  • filer address,
  • type of return,
  • statement that extension request is for providing statements to recipients,
  • reason for delay, and
  • signature of the filer.

If an extension is granted, it will generally be for a maximum of 30 extra days. For more information see http://www.irs.gov/pub/irs-prior/i109495c–2015.pdf.