The new deadline dates are as follows:
- Forms 1094-B and 1095-C sent to individuals: March 2, 2021
- Forms 1094-B and 1094-C paper filing to IRS: March 1, 2021
- Forms 1094-B and 1094-C electronic filing to IRS: March 31, 2021
The IRS has indicated that they will not accept any requests for extensions beyond the above-listed 30-day extension for sending forms to individuals. There will also be no extension to the standard filing dates for 1094-B and 1094-C forms.
This applies to all Applicable Large Employers (ALEs). The employer mandate remains in effect, as does the reporting requirements. Employers who sponsor a self-insured plan are still required to complete Part III of Form 1095-C for any full-time employee enrolled in that plan in 2020. ALEs must provide Form 1095-C to individuals. If the plan is fully insured, the insurance carrier will also provide Form 1095-B to covered individuals. ALEs with a self-insured plan (including level-funded) have all reporting information included in the 1095-C. Individuals will not receive a Form 1095-B. Non-ALEs that sponsor a self-funded plan must provide individuals with a 1095-B form.
A copy of Notice 2020-76 can be found here.