ACA Reporting Deadlines Quickly Approaching

Affordable Care Act (ACA) reporting under Section 6055 and Section 6056 for the 2020 calendar year is due in early 2021.  Specifically, reporting entities must:

  • File returns with the IRS by March 1, 2021, since Feb. 28, 2021, is a Sunday (or March 31, 2021, if filing electronically); and
  • Furnish statements to individuals by March 2, 2021.

Originally, individual statements were due by Jan. 31, 2021. However, on Oct. 2, 2020, the Internal Revenue Service (IRS) issued Notice 2020-76 to extend the furnishing deadline.

Notice 2020-76 does not extend the due date for filing forms with the IRS for 2020. Notice 2020-76 also provides additional penalty relief related to furnishing forms to individuals under Section 6055.

Action Steps

Despite the delay, the IRS is encouraging reporting entities to furnish statements as soon as they are able. No request or other documentation is required to take advantage of the extended deadline.

Section 6055 and 6056 Reporting

  • Section 6055 applies to providers of minimum essential coverage (MEC), such as health insurance issuers and employers with self-insured health plans. These entities generally use Forms 1094-B and 1095-B to report information about the coverage they provided during the previous year.
  • Section 6056 applies to applicable large employers (ALEs)—generally, those employers with 50 or more full-time employees, including full-time equivalents, in the previous year. ALEs use Forms 1094-C and 1095-C to report information relating to the health coverage that they offer (or do not offer) to their full-time employees.

The ACA’s individual mandate penalty was reduced to zero beginning in 2019. As a result, the IRS has been studying whether and how the Section 6055 reporting requirements should change, if at all, for future years. Despite the elimination of the individual mandate penalty, Section 6055 reporting continues to be required, although transition relief from penalties is available in some situations, as described below. Under this relief, individual statements do not have to be furnished if certain requirements are met.


Standard Deadlines

Generally, forms must be filed with the IRS annually, no later than Feb. 28 (March 31, if filed electronically) of the year following the calendar year to which the return relates. In addition, reporting entities must also furnish statements annually to each individual who is provided MEC (under Section 6055), and each of the ALE’s full-time employees (under Section 6056). Individual statements are generally due on or before Jan. 31 of the year immediately following the calendar year to which the statements relate.
As noted above, individual statements do not have to be provided under Section 6055 if certain requirements are met.
However, filing with the IRS is still required, and this relief does not apply to Section 6056.


Extended Furnishing Deadline

The IRS has again determined that some employers, insurers and other providers of MEC need additional time to gather and analyze the information, and prepare 2020 Forms 1095-B and 1095-C to be furnished to individuals. For 2020, the furnishing deadline was Feb. 1, 2021, since Jan. 31, 2021, is a Sunday. Notice 2020-76 provides an additional 30 days for furnishing the 2020 Form 1095-B and Form 1095-C, extending the due date from Feb. 1, 2021, to March 2, 2021.

Despite the delay, employers and other coverage providers are encouraged to furnish 2020 statements to individuals as soon as they are able. 

Filers are not required to submit any request or other documentation to the IRS to take advantage of the extended furnishing due date provided by Notice 2020-76. Because this extended furnishing deadline applies automatically to all reporting entities, the IRS will not grant additional extensions of time of up to 30 days to furnish Forms 1095-B and 1095-C. As a result, the IRS will not formally respond to any requests that have already been submitted for 30-day extensions of time to furnish statements for 2020.


Impact on the Filing Deadline

The IRS has determined that there is no need for additional time for employers, insurers and other providers of MEC to file 2020 forms with the IRS. Therefore, Notice 2020-76 does not extend the due date for filing Forms 1094-B, 1095-B, 1094-C or 1095-C with the IRS for 2020.

This due date remains:

  • March 1, 2021, if filing on paper (since Feb. 28, 2021, is a Sunday); or
  • March 31, 2021, if filing electronically.

Because the due dates are unchanged, potential automatic extensions of time for filing information returns are still available under the normal rules by submitting a Form 8809. The notice also does not affect the rules regarding additional extensions of time to file under certain hardship conditions.


Penalty Relief Regarding the Furnishing Requirement Under Section 6055 for 2020

The individual mandate penalty has been reduced to zero, beginning in 2019. As a result, an individual does not need the information on Form 1095-B in order to calculate his or her federal tax liability or file a federal income tax return. However, reporting entities required to furnish Form 1095-B to individuals must continue to expend resources to do so.

Therefore, Notice 2020-76 provides relief from the penalty for failing to furnish a statement to individuals as required under Section 6055 for 2020 in certain cases. Specifically, the IRS will not assess a penalty under Section 6722 against reporting entities for failing to furnish a Form 1095-B to responsible individuals in cases where the following two conditions are met:

  • The reporting entity prominently posts a notice on its website stating that responsible individuals may receive a copy of their 2020 Form 1095-B upon request, accompanied by an email address and a physical address to which a request may be sent, as well as a telephone number that responsible individuals can use to contact the reporting entity with any questions; and
  • The reporting entity furnishes a 2020 Form 1095-B to any responsible individual upon request within 30 days of the date the request is received. The reporting entity may furnish these statements electronically if it meets the requirements for electronic furnishing.

ALEs that offer self-insured health plans are generally required to use Form 1095-C, Part III, to meet the Section 6055 reporting requirements, instead of Form 1095-B. This 2020 Section 6055 furnishing penalty relief does not extend to the requirement to furnish Forms 1095-C to full-time employees. As a result, for full-time employees enrolled in self-insured health plans, penalties will continue to be assessed consistent with prior enforcement policies for any failure by ALEs to furnish Form 1095-C, including Part III, according to the applicable instructions. However, the 2020 Section 6055 furnishing penalty relief does extend to the requirement to furnish the Form 1095-C to any non-full-time employees enrolled in an ALE’s self-insured health plan, subject to the requirements of the 2020 Section 6055 furnishing penalty relief.

The 2020 Section 6055 furnishing penalty relief also does not affect the requirement or the deadline to file the 2020 Forms 1094-B, 1095-B, 1094-C or 1095-C, as applicable, with the IRS.

Clearing Up COVID Confusion

The Workplace Routine

For many, getting back to work is a long-awaited blessing. However, as we have seen COVID-19 cases spike across Ohio over the last several days, business-as-usual it is not. More employers and employees are working to meet the challenges of COVID-19 and are attempting to understand how to properly respond to COVID-19 incidents.

Although resources related to handling COVID-19 are vast, many employers continue to be unsure of what is necessary to minimize risk to employees and others. For that reason, we thought it may be helpful to bottom-line some workplace best practices, particularly for responding to situations where someone has been in “close contact” with a person or persons with COVID-19.

Download the Employer COVID-19 Checklist

First of all, where did we get our information?

The Centers for Disease Control and Prevention (“CDC”) has developed a raft of guidelines to address responding to possible exposure to COVID-19. We additionally consulted the resources available to assist employers through the Ohio Department of Health dedicated Coronavirus website.

Who can you trust?

Unfortunately, we have a pandemic that has been politicized creating a lot of hyper-partisan back and forth. Ultimately, this has led to a confusing landscape with people unsure of what to listen to and who to trust. The State of Ohio has gone through great lengths to help employers and employees in every field understand how to implement and innovate under the threat of COVID-19.

What is “close contact” with COVID-19?

The CDC has issued guidance regarding the proper response to situations where an individual has been in “close contact” with a person with COVID-19, which they updated in late September 2020. “Close contact” is defined by both the CDC as spending at least 15 minutes within six feet of a person with a confirmed case of COVID-19, or a direct exposure to possibly infected droplets of saliva or nasal mucus (e.g., being sneezed or coughed on in the face).

“Close Contact” Bottom Line

  • If a person does not have COVID-19 symptoms but has had “close contact”, the person should remain in self-quarantine at home for 14 days from the last exposure if the person has tested negative (or has not been tested);
  • If the person has a positive test but no symptoms, he or she should stay home in quarantine for 10 days after the test.
  • If a person has had both close contact and COVID-19 symptoms, the person (regardless of COVID-19 test results) should stay in self-isolation for at least 10 days since the onset of symptoms and until at least 24 hours have passed with no fever (without medications) and with the improvement of the other symptoms.
  • In addition to the above, new therapeutics are hitting treatment facilities showing merit for shortening the cycle. If in doubt, trust your health professionals to provide guidance on when it is safe to return to work.

Download the Potentially Exposed? Checklist

“But, I was wearing a mask”…

Just because an employee was wearing a mask when they came in “close contact” does not mean they can skip quarantine procedures. While wearing a mask aids in the fight to control COVID-19, the CDC guidance does not give one a “pass” from the quarantine requirements due to the fact that one was wearing a mask when in close contact with a person with COVID-19.  The same quarantine requirements still apply.

“But, I tested negative”…

Many employers are asking that employees that have been in “close contact” to be tested before returning to work. While this is a good step, it has caused some confusion. Given that the virus can develop and symptoms may not appear for up to fourteen days post-exposure; being exposed and then testing negative the next day does not mean an employee is in the clear. Simply put, even if an employee tests negative for COVID-19 or feels healthy, they should quarantine if they have been in “close contact” with someone with COVID-19. Today’s negative test can become tomorrow’s positive test.

“I vacationed or traveled to a hot spot, now what?”

Hot spots are popping up in a variety of areas across the country. If an employee travels for personal or professional reasons to a COVID-19 hot spot (classified as such due to the high rate of spread in the area), a traveler is exempt from the self-quarantine requirement if he or she has had a negative COVID-19 test in the seventy-two (72) hours prior to arrival back in Ohio or since returning.  However, if while visiting a hot spot a person was in “close contact” with someone with COVID-19, then it is recommended to follow the CDC guidelines for potential exposure.

More Resources Available

Ohio Department of Health, as mentioned at the top of this post, has assembled many resources for employers. With the September 14th law, HB 606, Ohio Governor Mike DeWine provided employers legal protections when it comes to their efforts to stem the spread of COVID-19, making Ohio one of a growing number of states granting similar civil immunity. However, it is important to note, HB 606 does not offer blanket protection for employers, as it additionally provides protections for employees who can prove “reckless disregard for consequences” by an employer.

One particularly useful area of resources on the Ohio Department of Health website is a section dedicated to common questions around COVID-19, as well as a number of downloadable checklists and employer resources. We would encourage you to check that out: COVID-19 Checklists

Saxon Gives Back

Community Strong: FamiliesFORWARD

Saxon took time out to give back by assembling school supply kits for FamiliesFORWARD.

FamiliesFORWARD is a neighborhood-based resource center devoted to helping children reach their full potential through many programs and partnerships within the community. We invite you to take a few moments to learn more about the FamiliesFORWARD mission and how you can get involved.

How You Can Help

Dayton Office with Beavercreek chamber ribbon cutting group photo

Saxon Financial Services Expands to Open Office in Dayton

Saxon Financial Services has broadens Ohio market footprint with expanded services and accessibility for Dayton area customers. COVID-19 related precautions and protocols have been established to protect staff and community while providing personal, friendly expertise to Dayton-area customers. Read on to learn more about this exciting announcement.

Dayton, Ohio – Saxon Financial Services is excited to announce the expansion of offices into the Dayton, Ohio area. This new office will be able to provide services such as: Employee Benefits, Supplemental Benefits and Corporate Retirement Planning (401, 403, Simple, SEPs). Eventually, Saxon will expand their individual wealth management team to the Dayton offices, too.

“Expansion in the Dayton market is a deliverable to our Dayton clients that has been in the works for some time, so I am very excited to have a physical presence in Dayton,” states Jamie Charlton, CEO at Saxon Financial Services.

Saxon has had the opportunity to maintain client relationships in Dayton and its surrounding suburbs for many years. Therefore, Dayton remains an important aspect of Saxon’s growth strategy. The success of Kettering native and Saxon Group Benefits Consultant, Kelley Bell, in the Dayton market during the past three years has provided Saxon the ability to maintain an active presence in the Dayton marketplace. The goal is to make Dayton aware they are fully committed to the communities they work in and serve. Kelley will be personally involved and in charge of their new Dayton office in Beavercreek Office Suites starting July 1, 2020.

Opening During COVID

Saxon is taking every caution they can to maintain a healthy and safe environment for each employee and client that walks through their doors. Saxon takes the recent outbreak of the COVID-19 virus seriously, and they continue to adhere to the rules set forth by Governor DeWine’s office. As a facilitator of client’s medical plans, they have been open the duration of the epidemic to ensure they are able to address clients’ concerns. During this time, they are allowing their staff the choice of working from home.

“As a facilitator of healthcare plans, we have seen the impact that COVID is having not only on the health of individuals but also small businesses. This pandemic has affected everyone on all levels. I have challenged our team at Saxon with the goal to make the life transitions people are experiencing as smooth as possible. This situation is not only creating physical maladies but is taking a toll on the mental aspect of everyone. It is crucial for everyone to understand the resources available to maintain their physical and mental well-being,” explains Charlton.

Overall, Saxon is excited to be able to expand into the area of Dayton.

“The expansion of Saxon to the Dayton market is an exciting time for our firm. Given our past and current success in this market, it is a move that simply makes sense. I am further excited to have Kelley Bell serving as our market leader in this space. Kelley was born and raised in Dayton, and she has always called Dayton home. I know she will continue to deliver to the Dayton small business community impactful solutions to the ever changing employee landscape,” states Charlton.

About Dayton Market Leader

Kelley Bell, Dayton Market

Kelley Bell has over 25 years of experience in the financial industry. Kelley enjoys partnering with business owners and those responsible for choosing benefits for their employees. She understands that every business is unique and is dedicated, accessible and proactive in serving the needs of each client. Kelley has a strong business network and serves the Dayton and Cincinnati markets. She has recently been named Dayton Chamber’s 2019 Ambassador of the Year award recipient. This award honors the ambassador who demonstrated exemplary efforts in working with members each year.

About Saxon Financial Services

From employee benefits and insurance to wealth management and retirement, Saxon’s team of experts is knowledgeable on cutting-edge techniques that focus on controlling rising healthcare costs while still delivering solutions with compassion and transparency to you and your organization. With caring, knowledgeable experts working to service your needs, Saxon brings an element of strategic innovation to the conversation. We strive daily to lay the foundation for long-term relationships with our clients because we care about being a partner you can count on.


For more information, you can contact Brianna Louder, Saxon’s Marketing and Community Outreach Coordinator, at or 513.774.5480

BREAKING: Health Care Bill Moves to Debate on Senate Floor with 51-50 vote

In case you haven't heard, the motion to debate a version of the Health Care Bill after multiple renditions that has been dragging it's way through congress and stalled in the Senate has just been successfully passed with a narrow vote of 51-50 in favor with Vice President Pence casting the tie-breaking vote. The bill has a long road ahead and likely a vast number of revisions.

You can keep an eye on relevant news from our Navigator page right here on our own website.  We know it is overwhelming to try to keep up with all of the news from all of the disparate sources. Our Navigator resource simply works to curate content from a variety of trusted, non-partisan sites across the internet and bring them to a central location to provide you a trusted place to stay-up-to-date on Health Care news at a glance.


Source: Wall Street Journal, Daniel Nasaw,Michelle Hackman

Access Live Updates on the Motion Here:

Moments ago:

Vice President Mike Pence just broke the 50-50 tie. The motion to proceed passes and the Senate will now begin debate on a bill to repeal and replace the Affordable Care Act.

With the motion passed, Senators will now proceed to 20 hours of debate on several proposals repealing parts of the 2010 Affordable Care Act, including their replacement package and a separate bill repealing the law with a two-year delay.

They are expected to debate numerous amendments – not counted toward the 20 hours – including proposals put forward by Democrats....