Now that most “Applicable Large Employer” school districts and ESUs (whose
“large employer number” is 50 or greater) have begun filling out the 1094-C
and 1095-C reporting documents, the IRS has extended the deadlines to file
The 1095-C, which was previously due by January 31, 2016, is now due to
employees and the IRS by March 31, 2016.
The 1094-C, which was due by February 29, 2016 if filed in paper form and
March 31, 2016 if filed electronically, is now due either May 31, 2016
(paper) or June 30, 2016 (electronically).
The IRS issued Notice 2016-4 on December 28, 2015 to explain the
extensions and provide guidance to individuals who may elect to file their
tax returns before their employers issue their 1095-C forms. Keep in mind
that the 1095-C’s will be made a part of an individual’s income tax filings,
much like the W-2. If you have been using this time to fill out the reporting
forms over the break without students and staff in the building, we think
you’ve made the smart decisions. While you now have additional time to file
these reports, hopefully you will avoid confusion and a lot of questions from
staff members by completing them early!
If you have questions or concerns about these or any other issues related to
the PPACA reporting obligations, we recommend that you consult with your
school district’s attorney or call Karen, Steve, or Bobby.