By BLR Legal Editor Jennifer Carsen, JD
While the IRS thoughtfully extended the filing deadline for Forms 1094-B, 1094-C, and 1095-C to May 31, 2016 (if filing nonelectronically) and to June 30, 2016 (if filing electronically), you are hopefully long done with the worst of the process—because you had to get Forms 1095-B and 1095-C to your employees by the end of March.
Now there’s even more fun employers can look forward to: The Federally-Facilitated Marketplace’s (FFM) 2016 Employer Notice Program, run by the Centers for Medicare and Medicaid Services (CMS).
What’s that, you may ask? It’s a program you may find yourself a less-than-enthusiastic participant in if you fail to meet your obligations under the play-or-pay rules—or, worse, if the government simply believes you failed to do so.