Guest Author Jeff DeVree: Deadlines extended for Affordable Care Act

Last week, the IRS exDeVreeJ_webtended the due dates for providing ACA reporting forms to employees and filing the forms with the IRS. The extension applies to the forms for 2015, which are due in 2016.

  • The due date for providing the 1095 forms to employees has been extended from February 1 to March 31.
  • The due dates for filing the 1094 and 1095 forms with the IRS have been extended from February 29 to March 31 for forms filed on paper and from March 31 to June 30 for forms filed electronically.

This is good news for employers, insurers, and others who are required to prepare, provide, and file these forms. They will get much needed additional time.

It’s not so good news for employees and other individuals who need to receive the forms in order to claim the premium tax credit on their tax returns. Imagine how employees eager to get their tax refunds would feel about a two-month delay in receiving W-2s. So, for 2015 only, the IRS will allow employees to rely on “other information received from employers about their offers of coverage” in order to claim the premium tax credit on their returns.


About the Author:

Jeff DeVree is a partner at Varnum LLP and leads the employee benefits practice team. He has 25 years of experience working with employers, executives and third-party administrators on a wide range of employee benefit, executive compensation and individual retirement matters, including plan design, plan administration, benefit plan disputes and tax planning for retirement.

For more updates from Jeff and Varnum’s employee benefits team, visit