IRS Notice 2020-76: Transitional Relief for Health Coverage Information Reporting ― Now Due March 2, 2021

On October 2, 2020, the Internal Revenue Service (“IRS”) issued an advance version of Notice 2020-76 that extends the due date from January 31, 2021, to March 2, 2021 for certain 2020 health coverage reporting under Internal Revenue Code (“IRC”) Sections 6055 and 6056.

Notice 2020-76 extends the due dates under Sections 6055 and 6056 to March 2, 2021, for insurers, self-insuring employers, applicable large employers, and certain other providers of minimum essential coverage to furnish to individuals the 2020 Form 1095-B, Health Coverage, and the 2020 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage.

Notice 2020-76 states that the IRS will not impose a penalty under Section 6722 for failures to furnish a Form 1095-B to responsible individuals and also provides a final extension of transitional good-faith relief from Sections 6721 and 6722 penalties to the 2020 information reporting requirements under Sections 6055 and 6056.

As background:

  • Section 6055 requires health insurance issuers, self-insuring employers, government agencies, and other providers of minimum essential coverage to file and furnish annual information returns and statements regarding coverage provided.
  • Section 6056 requires applicable large employers (generally those with 50 or more full-time employees, including full-time equivalent employees, in the previous year) to file and furnish annual information returns and statements relating to the health insurance, if any, that the employer offers to its full-time employees.

According to Notice 2020-76, the IRS and Treasury Department have determined that a substantial number of employers, insurers, and other providers of minimum essential coverage need additional time to complete the 2020 Forms 1095-B and 1095-C that are to be provided to individuals.

It is important to note that Notice 2020-76 does not extend the due date for filing Forms 1094-B, 1095-B, 1094-C or 1095-C for 2020 with the IRS.

In addition, Notice 2020-76 does not affect the provisions regarding an automatic extension of time for filing information returns and does not affect the provisions regarding additional extensions of time to file.


Author: Emily Langdon

This article has been prepared for general information purposes and (1) does not create or constitute an attorney-client relationship, (2) is not intended as a solicitation, (3) is not intended to convey or constitute legal advice, and (4) is not a substitute for obtaining legal advice from a qualified attorney. Always seek professional counsel prior to taking action.