Need to know: IRS extends 1095-B and 1095-C reporting deadline and other important filing news

On Nov. 29, 2018, the IRS issued guidance extending the 1095 reporting deadline to March 4, 2019 that requires insurers and employers to furnish individuals with their 1095-B or 1095-C to substantiate minimum essential coverage for 2018. Insurers and employers are encouraged to furnish 2018 statements as soon as they are able. As of Jan. 31, 2019, UnitedHealthcare mailed all 1095-B forms to fully insured subscribers. Members who requested to access their 1095-B forms online can do so at

This guidance does not provide an extension for employers or insurers to file required forms 1094-B, 1095-B, 1094-C or 1095-C with the IRS. 

Employees with fully insured plans who were eligible for coverage for at least one month in 2018 must receive a 1095-B form from their insurance carrier. For fully insured customers, UnitedHealthcare sends these 1095-B forms directly to employees. They are not mailed to the employers.  The employer may not request forms for their employees nor receive a report of employees who receive a form. If the member misplaces the form, they may obtain a copy of their 1095 on the member portal. They may also call the phone number for customer service on the back of their ID card. 

By March 4, 2019, self-funded (ASO) customers must provide their employees with a:

  • 1095-B form if they are a small employer with 1 to 49 full time equivalent employees (FTEs).
  • 1095-C form if they are an Applicable Large Employer (ALE) with 50 or more FTEs.

Reminder IRS filing dates have not been extended.  

The recent IRS guidance does not provide an extension for employers or insurers to file required forms 1094-B, 1095-B, 1094-C or 1095-C with the IRS. The due date for filing the 2018 forms 1094-B, 1095-B, 1094-C, or 1095-C remains:

  • Feb. 28, 2019, if not filing electronically.
  • April 1, 2019, if filing electronically.

Individual Reporting Requirements

The 2019 reporting year (for 2018 tax year), individuals are still subject to a penalty if they did not comply with the shared responsibility requirements of the Affordable Care Act (ACA), sometimes referred to as the individual mandate.

The IRS will not accept individual tax returns that do not include the following information:

  • Had minimum essential coverage (MEC) for the year.
  • Qualified for an exemption from having health coverage.
  • Are paying the individual shared responsibility payment.

Individuals are required to: 

  • Indicate coverage by responding on line 61 on Form 1040.
  • Include any exemptions of financial responsibility information with their tax return.
  • Pay what they may owe when they file their tax return‎.

Beginning in 2019 (for taxes reported in 2020), the individual mandate penalties have been reduced to 0. The latest IRS guidance indicates that they are “studying whether and how the reporting requirements under section 6055 should change, if at all, for future years.”