The U.S. Department of the Treasury and the Internal Revenue Service (IRS) announced a limited extension of the early 2016 due dates for the 2015 information reporting requirements for employers and insurers under the Affordable Care Act (ACA). This is the first year that employers and insurers are required to report certain information about health coverage to employees, other individuals, and the IRS.

The IRS is prepared to begin accepting this reporting in January, and employers and insurers are encouraged to begin reporting to employees and other individuals as soon as possible. However, in response to stakeholder feedback, this extension will provide employers and insurers a limited additional period of time to meet these requirements, while maintaining the ACA reporting requirement for 2015.

Specifically, this notice extends the February 1 due date by two months to March 31, 2016 for employers and issuers to provide individuals with forms reporting on offers of health coverage and coverage provided. It also extends the February 29 and March 31 deadlines for reporting this information to the IRS (by paper or electronically, respectively) by three months for due dates of May 31, 2016 and June 30, 2016.

The vast majority of individual taxpayers will not be affected by this extension. Like last tax filing season, most individuals will simply check a box on their tax return indicating they had health coverage for the entire year. These forms provide individuals with a record of their health coverage but do not need to be attached to the tax return. This notice also provides guidance to the limited number of individuals who might be affected by the extension. In particular, individuals who file their tax returns relying on other information about their health care do not need to amend their returns. The additional time provided to employers and insurers will also not materially affect the IRS’s ability to use the information provided to verify compliance.

This extension is intended to provide employers, insurers, and other providers of minimum essential coverage additional time to implement systems and procedures in this first year in order to gather, analyze, and report information about the health coverage they offer and provide.