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Not Ready to File the Forms 1094-C and 1095-C with the IRS? How to File an Extension

February 24, 2017

The deadline to file the Forms 1094-C and 1095-C for paper filers, February 28, 2017, is only days away. An employer who has elected to, or is required to, file electronically will have until March 31, 2017 to file the Forms 1094-C and 1095-C. If an employer is not prepared by the requisite deadline, the employer may receive an automatic 30 day extension by filing a Form 8809 with the IRS. This extends the paper deadline until March 30, 2017 and the electronic deadline to May 1, 2017. This article provides basic instructions regarding how an employer should complete the Form 8809.

First, and importantly, the Form 8809 must be filed with the IRS before the due date (February 28, 2017 for paper filers or March 31, 2017 for electronic filers). To receive the automatic 30 day extension, it is critical the employer files the Form 8809 before the original due date. The good news is the Form 8809 is simple to complete.

In line one the employer will enter its name and address along with a contact name and number in case the IRS needs to follow up regarding the extension. In line two the employer will enter its employer identification number (EIN). Line three requires the employer to check whether it will file the Forms 1094-C and 1095-C electronically or on paper. If the employer plans on filing the Forms 1094-C and 1095-C using both methods (something that would be completely unnecessary), two Forms 8809 need to be filed with the IRS.

The only other pertinent box for filing an extension for the Forms 1094-C and 1095-C is line 6. The employer should check the “1094-C, 1095-C” box in the far right column. Finally, a representative of the employer will need to sign and date the Form 8809 under penalties of perjury. It is really that simple to get 30 extra days to file the Forms 1094-C and 1095-C with the IRS!

An employer has two options to file the Form 8809 with the IRS. The IRS prefers that an employer completes the Form through the IRS’ FIRE system at This system is user friendly and can be completed in a matter of minutes. Alternatively, an employer can complete the Form 8809 on paper. If an employer elects the paper method, the Form 8809 should be sent to:

Internal Revenue Service
Attn: Extension of Time Coordinator
240 Murall Drive, Mail Stop 4360
Kearneysville, WV 25430

Any employer who does not know if it can meet the deadline for filing the Forms 1094-C and 1095-C, should file an extension. Please let us know if you have any questions or concerns regarding the extension process or filing the Forms 1094-C and 1095-C.

About the author – Ryan Moulder serves as General Counsel at Accord Systems, LLC and is a Partner at Health Care Attorney's P.C. Ryan received his LL.M. from Georgetown University Law Center and his J.D. from Saint Louis University School of Law. He has distinguished himself as a leader in the Affordable Care Act arena and has written and spoken on a variety of ACA topics as it relates to compliance for companies.

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