This is a last reminder (until next year) of the due dates for IRS reporting under the ACA. Filing the 2016 Forms 1094-B, 1095-B, 1094-C and 1095-C with the IRS must be completed no later than February 28, if not filing electronically, and March 31 if filing electronically. Further, employee statements required under the ACA are due no later than March 2.
For the 2016 reports due in 2017, there will be no further extensions of these deadlines. The 30-day extension to furnish these reports that may be granted in a “normal” year will not be granted this year, as the extensions that the IRS previously granted are more generous. Additionally, the IRS has carried over the “good faith effort” transition relief granted last year.
Medicare Part D Disclosure Notices
Entities that provide prescription drug coverage to Medicare Part D eligible individuals must disclose to the Centers for Medicare and Medicaid Services (CMS) whether the coverage is "creditable prescription drug coverage." This disclosure is required whether the entity's coverage is primary or secondary to Medicare. Entities must disclose creditable coverage status to CMS using the online Disclosure to CMS Form found here. The disclosure should be completed annually no later than 60 days from the beginning of a plan year (contract year/renewal year), within 30 days after termination of a prescription drug plan, or within 30 days after any change in creditable coverage status.
Sponsors of non-calendar year plans should mark their calendars to make sure the disclosure to CMS is made within 60 days after the beginning of the plan year (e.g., for an April 1 plan year, the CMS online disclosure should be made no later than May 30). An entity that does not offer outpatient prescription drug benefits to any Part D eligible individual on the first day of its plan year is not required to complete the CMS disclosure form for that plan year.
For guidance on Creditable Coverage Disclosure to CMS, download the document below or visit the CMS website. We have also provided resources to help you finalize your reports before the due date and a sample letter explaining the 1095-C form to employees.