Question: Our company is an applicable large employer (ALE), and we sponsor a fully insured group health plan. We have to file Forms 1094-C and 1095-C for the 2017 calendar year. When are these forms due this year?
Answer: Applicable large employers must:
1. Report to the IRS whether they offered their full-time employees and these employees’ dependents the opportunity to enroll in minimum essential coverage under an eligible employer-sponsored plan, and
2. Provide certain other information that the IRS uses to administer employer shared responsibility.
Also, applicable large employers must provide a related written statement to full-time employees. (Additional requirements apply to applicable large employers that sponsor self-insured health plans.) Form 1094-C is a transmittal that satisfies these requirements in combination with Form 1095-C. You need to be aware of three deadlines:
- February 28, 2018. This is the deadline for filing the Form 1094-C transmittal (and copies of related Forms 1095-C) with the IRS, if you’re filing on paper.
- March 2, 2018. This is the deadline for furnishing the written statement (Form 1095-C) to full-time employees, reflecting the IRS’s decision, announced in Notice 2018-06, to provide a blanket 30-day extension of the statutory deadline for 2017 forms. Further extensions of this deadline aren’t available.
- April 2, 2018. This is the deadline for filing the Form 1094-C transmittal (and copies of related Forms 1095-C) with the IRS, if you’re filing electronically. Electronic filing is mandatory if you’re required to file 250 or more Forms 1095-C for the 2017 calendar year. Otherwise, electronic filing is encouraged, but not required. Note: In 2018, the normal deadline of March 31 falls on a Saturday, so the deadline moves to the next business day.
Whether you’re a paper or electronic filer, you can apply for an automatic 30-day extension of the IRS filing deadline. However, the extension is available only if you file Form 8809 before the applicable due date. Contact Filler & Associates for more information.