By - December 14, 2021

Recent ACA Updates to IRS Deadlines and Good-Faith Effort


IRS Grants 2021 Extension and Proposes Permanent 1095-C Print Extension

The IRS is granting an extension for the 2021 tax year and proposing to make this extension permanent for future tax years. The proposed regulations would permanently extend the deadline for furnishing a given year’s Forms 1095-B and 1095-C to individuals. The extension is for 30 days after January 31, 2021, and ongoing years (or the next business day, if the 30th day falls on a Saturday, Sunday, or legal holiday). The proposed permanent extension generally aligns with past extensions granted each year since the reporting requirements took effect. It would replace both the 30-day extension that may be requested for good cause, and the IRS’s ability to provide blanket automatic extensions.

Upcoming ACA Deadlines to mark on your calendar:

February 28, 2022: Paper filing deadline. This only applies to employers with 250 or less 1095-C returns. If you have over 250 1095-C returns, you must file electronically.

March 2, 2022: New annual furnishing deadline for 1095-C forms to ACA full-time employees. This used to be due January 31, but a new IRS rule provides employers with an automatic 30-day extension.  

March 31, 2022: File the 1094-C and 1095-C information electronically to IRS.

State Mandates: Deadlines for mailing forms to California and Vermont residents currently remains January 31, 2022. Learn more about state mandates and guidelines here.

Good-Faith Relief Eliminated

Good-Faith Relief was eliminated by the IRS. The Good-Faith Relief applied to taxpayers who reported incorrect or incomplete information if they could adequately demonstrate to the IRS that a good-faith effort had been made to comply. The IRS concluded that 5 years of understanding ACA requirements was enough to create and establish a process to submit accurate information. They will no longer be accepting an explanation of good-faith for incorrect or incomplete submissions.



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