Employer Deadlines for Insurance Under the Affordable Care Act Extended by IRS

The deadline for employers to electronically file the so-called 1094 forms for 2015 which provide coverage information to the IRS was extended to June 30, 2016 from March 31, while non-electronic form reporting was delayed to May 31, 2016 from Feb. 29.  According to IRS.gov:

“The due dates for the 2015 information reporting requirements under I.R.C. §§ 6055 and 6056, have been extended.

*The due date for furnishing the 2015 Form 1095-B, Health Coverage, was changed from January 31, 2016, to March 31, 2016; and

*The due date for filing with the Service the 2015 Form 1094-B, Transmittal of Health Coverage Information Returns, and the 2015 Form 1095-B, Health Coverage, was changed from February 29, 2016, to May 31, 2016. If filing electronically, the due date was changed from March 31, 2016, to June 30, 2016.

*The due date for furnishing the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, was changed from January 31, 2016, to March 31, 2016; and

*The due date for filing with the Service the 2015 Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, and the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, was changed from February 29, 2016, to May 31, 2016. If filing electronically, the due date was changed from March 31, 2016, to June 30, 2016.

As a result of these extensions, individuals might not receive a Form 1095-B or Form 1095-C by the time they file their 2015 tax returns. For further guidance, please see Notice 2016-04.

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Michael Arrigo

Michael is Managing Partner & CEO of No World Borders, a leading healthcare management and IT consulting firm. He serves as an expert witness in Federal and State Court and was recently ruled as an expert by a 9th Circuit Federal Judge. He serves as a patent expert witness on intellectual property disputes, both as a Technical Expert and a Damages expert. He leads a team that provides Cybersecurity best practices for healthcare clients, ICD-10 Consulting, Meaningful Use of Electronic Health Records. He advises legal teams as an expert witness in HIPAA Privacy and Security, medical coding and billing and usual and customary cost of care, the Affordable Care Act and benefits enrollment, white collar crime, False Claims Act, Anti-Kickback, Stark Law, Insurance Fraud, payor-provider disputes, and consults to venture capital and private equity firms on mHealth, Cloud Computing in Healthcare, and Software as a Service. He advises self-insured employers on cost of care and regulations. Arrigo was recently retained by the U.S. Department of Justice (DOJ) regarding a significant false claims act investigation. He has provided opinions on over $1 billion in health care claims and due diligence on over $8 billion in healthcare mergers and acquisitions. Education: UC Irvine - Economics and Computer Science, University of Southern California - Business, studies at Stanford Medical School - Biomedical Informatics, stutdies at Harvard Law School - Bioethics. Trained in over 10 medical specialties in medical billing and coding. Trained by U.S. Patent and Trademark Office (USPTO) and PTAB Judges on patent statutes, rules and case law (as a non-attorney to better advise clients on Technical and Damages aspects of patent construction and claims).

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