What employers want to know is, “Will Congress pass a bill to replace ACA before ACA 1095 & 1094 Reporting is due?” Not likely! No matter what happens in Congress for 2017, Applicable Large Employers (ALE) will likely be required to submit ACA Reports 1095 and 1094 in January. There is not enough time for anything to pass before the established deadlines. The IRS has not given any indication that they will not require these reports or assign fines if reports are not complete.
The New York times advised on Thursday; Republican Senators “unveiled a fresh proposal to repeal and replace the Affordable Care Act. Revising their bill to help hold down insurance costs for consumers while keeping a pair of taxes on high-income people that they had planned to eliminate.” Yet, “the measure was immediately imperiled when two Republican senators, moderate Susan Collins of Maine and conservative Rand Paul of Kentucky, announced they were not swayed and could hinder their ability to obtain enough votes to proceed.
As you are aware, 5500 reports are due within seven months after the beginning of the plan year for employers with 100 or more participants. If employers have a calendar year plan, July 31st is their deadline. There is an increase in fines for being late or not filing at all, so make sure you complete these reports on-time.
Important ACA Reporting Deadlines
Here are some significant dates to keep in mind for submitting ACA information for the 2019 tax year to the IRS to avoid being charged fines:
February 28, 2020: Deadline to file 1094-C / 1095-C schedules for 2019 if paper filing.
March 2, 2020 (Previously January 31): IRS deadline to furnish 1095-C schedules for 2019 to employees.
March 31, 2020: Deadline to file 1094-C / 1095-C schedules for 2019 if electronic filing.
July 31, 2020: Form 720 (PCORI) for plans that do not start after September 30, 2019, due to self-insured plans (includes self-insured employers.)
August 1, 2020: Late filing deadline to file 1094-C / 1095-C schedules for 2019.