ACA Updates from Scirocco Group

Delayed Reporting for 2015 Information Under IRC 6055 and 6056

IRS Notice 2016-4 extends due dates for both furnishing to individuals and filing with the IRS for insurers, employers, and other providers of Minimum Essential Coverage (MEC) and information reporting by Applicable Large Employers (ALEs).

  • – There is an automatic extension for furnishing Forms 1095-B and 1095-C to individuals from February 1, 2016 to March 31, 2016.
  • – If not filing electronically, there is an automatic delay for Forms 1094-B, 1095-B, 1094-C, and 1095-C from February 29, 2016 toMay 31, 2016.
  • – There is an automatic extension to file electronically for Forms 1094-B, 1095-B, 1094-C, and 1095-C with the IRS from March 31, 2016 toJune 30, 2016.

The notice also provides guidance to individuals who might not receive Forms B or C by the time they file their 2015 tax returns.

REMINDER: Employers who have 50 or more full-time employees including equivalents are considered ALEs. All ALEs are subject to Employer Reporting of 2015 information even if they qualified for Transitional Relief of the Employer Shared Responsibility / Play or Pay for 2015.

Self-insured employers that are not ALEs are subject to Form B reporting.

For further details regarding reporting, see our contact a Scirocco Group representative.

ACA Guidance: Two-Year Delay of the Cadillac Tax

President Obama signed federal legislation on December 18, 2015, which delays the Cadillac tax for two years.

In addition to delaying the Cadillac tax, the legislation provides the following:

  • – a two-year delay of the excise tax (aka the Cadillac tax) on high-cost plans (therefore, this will not be applicable in 2018 and 2019)
  • – a one year delay of the Health Insurance Tax (HIT will be applicable on 2017 premium)
  • – a suspension of the medical devices tax until December 31, 2017

For more details on federal health care reform, including information on taxes and provisions, visit

If you have any questions, contact your Scirocco Account Executive.