On December 28, 2015, the Internal Revenue Service (the “IRS”) extended the reporting requirement due dates for self-insured health plans and applicable large employers for 2015 coverage.

As background, employers that have more than 50 full-time equivalent employees, as well as employers that sponsor self-insured health plans, have to furnish Form 1095-C or Form 1095-B, respectively, to their employees by January 31 (February 1 for 2016) of the year following the year of coverage. The same employers must also file the IRS Form 1094-C or Form 1094-B, respectively, by February 28 (February 29 for 2016), or by March 31 if filed electronically.

Now, the deadline for furnishing these returns to individuals has been extended from February 1, 2016, to March 31, 2016. Furthermore, the deadline for filing these returns with the IRS has been extended from February 29, 2016, to May 31, 2016, if not filing electronically; and from March 31, 2016, to June 30, 2016, if filing electronically.

Employers that do not comply with these extended due dates may be subject to IRS penalties for failure to timely furnish and file.

For subsequent years, the deadlines continue to be January 31, February 28, and March 31, as applicable. Also, as a reminder, the “Cadillac Tax” was also postponed as explained in our 12/22/2015 client alert.

If you have any questions regarding these issues, please contact your Executive Compensation and Employee Benefits counsel at Smith, Gambrell & Russell, LLP.

This client alert is intended to inform clients and other interested parties about legal matters of current interest and is not intended as legal advice.