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IRS Announces Opening Date for Electronic Filing of 2018 Forms 1094 and 1095



AIR Production Start-up Schedule for Filing Season 2019/Tax Year 2018 (Dec. 28, 2018)

Available at

The IRS has announced that electronic filing of Affordable Care Act (ACA) information returns (Forms 1094/1095) for the 2018 tax year will become available on January 15, 2019, at approximately 9 a.m. Eastern time. As a reminder, Code §§ 6055 and 6056 require information reporting by health coverage providers and applicable large employers (ALEs). Electronic filing through the IRS’s ACA Information Returns (AIR) Program is mandatory for coverage providers and ALEs transmitting 250 or more individual information returns. (Forms 1095-B and 1095-C are counted separately for this purpose.) Filers can find helpful information on the AIR Program webpage, which includes a link to the system’s current operational status. Only the AIR Program test system is currently available; the “production” (live filing) system will not be operational for any tax years until the January 15 opening of the 2019 filing season. Prior-year returns, including corrections and replacements, can be electronically filed once the production system is operational.

Various publications and other resources related to filing Forms 1094 and 1095 have been updated for the 2018 tax year/2019 filing season. These include Publication 5165 (Guide for Electronically Filing Affordable Care Act (ACA) Information Returns for Software Developers and Transmitters (Processing Year 2019)), Publication 5164 (Test Package for Electronic Filers of Affordable Care Act (ACA) Information Returns (AIR) (Processing Year 2019)), Publication 5258 (Affordable Care Act (ACA) Information Returns (AIR) Submission Composition and Reference Guide), and Publication 5223 (General Rules and Specifications for Affordable Care Act Substitute Forms 1095-A, 1094-B, 1095-B, 1094-C, and 1095-C). Filers should be sure to use the most recent guidance when preparing filings.

EBIA Comment: Although the IRS extended—to March 4, 2019—the deadline for furnishing Forms 1095-B and 1095-C to individuals, no similar extension applies to filing with the IRS (see our Checkpoint article). Thus, the deadline for electronic filing is April 1, 2019. (Paper filings are due February 28, 2019.) For more information, see EBIA’s Form 1094/1095 Workbook—recently updated for the 2018 information returns—at Section X (“Filing With the IRS”). See also EBIA’s Health Care Reform manual at Sections XXVIII (“Shared Responsibility for Employers (Play or Pay Penalty Tax)”), XXXVI.C (“Information Reporting of Minimum Essential Coverage (Insurers and Employers That Self-Insure)”), and XXXVI.D (“Information Reporting of Employer-Sponsored Coverage (Applicable Large Employers)”). You may also be interested in our recorded webinar “1094/1095 Reporting for 2018” (recorded on 11/15/18).

Contributing Editors: EBIA Staff.

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