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The IRS has extended the due dates for the 2015 Affordable Care Act reporting requirements.

• 1094-B and 1094-C (transmittal form to the IRS): previously due on February 29, 2016 (paper filing) or March 31, 2016 (electronic filing); now due May 31, 2016 (paper) or June 30, 2016 (electronic).

• 1095-B and 1095-C (information statement to individuals): previously due to individuals on February 1, 2016; now due March 31, 2016.

The Departments of Labor, Treasury and HHS have issued additional Frequently Asked Questions (FAQs) regarding certain employer reimbursement of health coverage premiums.

The FAQs address arrangements where employers (i) reimburse employees for the cost of individual insurance plan coverage or (ii) offer cash to employees with high-risk claims who opt of the employer’s health plan. The FAQs provide that these arrangements are not in compliance with market reforms. Additionally, the FAQs specifically disallow an arrangement some vendors have promoted, whereby employers set up a Code Section 105 reimbursement plan to reimburse employees for individual insurance coverage (including Marketplace coverage for which the employee may have received premium tax credits).