The IRS has extended the deadline for providing 2018 Forms 1095-C to employees from January 31, 2019, to March 4, 2019. The IRS has also extended the "good-faith effort" standard to 2018 reporting. As in previous years, the IRS did not extend the deadline for filing 2018 Forms 1094-C and 1095-C with the IRS (leaving the deadline to file such reports with the IRS at February 28, 2019, for paper filers and April 1, 2019, for electronic filers).
No Additional Extensions for Providing Forms 1095-C to Employees. Because the IRS is providing an automatic extension for distributing 2018 Forms 1095-C to employees, no additional extensions will be permitted for employee reporting. However, employers may still obtain an automatic 30-day extension for filing their 2018 reporting with the IRS by submitting Form 8809 before the regular due date.
"Good-Faith Effort" Standard Continued for 2018. Significantly, the IRS also announced that the "good-faith effort" standard that has applied to previous years' reporting will continue to apply to 2018 reporting. This relief provides that 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.
Impact. This extension may provide employers with the time they need to complete the forms for 2018 and help ensure their accuracy. In addition, the extension of the "good-faith effort" standard will decrease the chances of an employer being subject to penalties for incorrectly completing its 2018 reporting. However, the IRS has previously indicated that "good-faith effort" generally requires that an employer correct errors it finds in forms after they have been distributed and/or filed.
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