Keeping with its annual tradition, the Internal Revenue Service (IRS) has once again extended the deadline for employers to provide their 2019 Forms 1095-C to employees from January 31, 2020, to March 2, 2020.

The IRS also announced:

• The “good-faith effort” standard that has applied to previous years’ reporting will continue to apply to an employer’s 2019 reporting. This means an employer will not be subject to penalties for providing incorrect or incomplete Forms 1094-C and 1095-C, as long as the employer makes a “good-faith effort” to comply with its reporting obligations.  The relief specifically applies to missing and inaccurate Social Security numbers and dates of birth, but does not apply to a failure to provide the reports to individuals or the IRS by the applicable deadline.
• Employers generally will still need to complete Part III of Form 1095-C – which reports whether an individual has complied with the Affordable Care Act’s individual coverage mandate – even though the federal tax penalty for failing to comply with the individual coverage mandate has been eliminated.

As in previous years, the IRS did not extend the deadline for filing 2019 Forms 1094-C and 1095-C with the IRS (leaving the deadline to file with the IRS at February 28, 2020, for paper filers and March 31, 2020, for electronic filers).

If you have any questions about this new IRS guidance, please contact your Executive Compensation and Employee Benefits counsel at Smith, Gambrell & Russell, LLP.