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.

If you have any questions regarding Notice 2020-76 and the relief provided, feel free to contact Emily Langdon at elangdon@fraserstryker.com.

 

Author: Emily Langdon

Emily R. Langdon

Emily R. Langdon

Partner

(402) 978-5386
elangdon@fraserstryker.com

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.