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ACA Deadlines & Penalties

Complying with ACA Reporting Deadlines

In 2016, employers got an extra two months to distribute forms to employees, and three more months to file with the IRS. The extensions aren’t as generous for 2017, but employers still have an extra 30 days to get 1095 copies to employees. The paper and electronic filing deadlines remain the same.

The timeline for ACA reporting in 2017 is:


Due to Recipient

Paper Filing

Electronic Filing

1095-C Mar. 2 Feb. 28 Mar. 31
  Feb. 28 Mar. 31

Remember: Form 1095-C provides specific health coverage details for employees, while the 1094-C acts as proof that an applicable large employer met the IRS requirements and the employer shared responsibility provision.

About electronic filing … not only is it a more efficient way to file with the IRS (giving you another month to do so), but it’s required if you file at least 250 forms. So if you’re a bigger business filing 250 or more forms, understand that e-filing is your only option.

Avoiding Filing Penalties

Obviously, you must comply with ACA reporting requirements — or risk steep penalties. Penalties can apply for a variety of reasons:

Failure to file
Failure to furnish recipient statements
Failure to file on time, and
Failure to file electronically when required to do so
(if filing 250 or more forms)

The IRS penalty for failing to file complete and accurate ACA forms by the deadline is $260 per form, with a maximum of about $3 million. Outright failure to distribute or file a 1905-C is twice as costly — a $500 fine per form — obviously, not something you want to mess around with. Please note that the IRS is offering “good faith transitional relief” from certain penalties in 2017, but only if you’ve made every effort to file correct forms according to the latest ACA reporting requirements.

Be Aware of the Employer Shared Responsibility Provision, Too

The IRS reporting deadlines aren’t the only dates employers need to heed. If you have 50 or more full-time (or full-time equivalent) employees, you must provide qualified health coverage to 95 percent of these employees to avoid liability under the ACA’s shared responsibility provision. This 95 percent requirement isn’t an average for the year, either, but for each month. If you below 95 percent for any given month, you’re at risk.

Shanna Wall, Esq.
Presented by: Shanna Wall, Esq.,
Compliance Attorney
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