Delays in implementing the employer mandate created the impression in some executives' minds that the mandate — and the form-filing requirements — would end up being delayed yet again, killed by a Republican-controlled Congress, or somehow stopped by a Supreme Court challenge. None of those things happened.
"I think there was a certain amount of denial going on," Elliott said.
Elliott, who left the IRS only three months ago, was in meetings with employers last year, when they expressed concern about their readiness to meet the form-related deadlines.
Some companies were already assembling their required data, but "you had some ones that called and said, 'Hey, what is this thing we are required to do?'" Elliott recalled.
Their concerns led to the Obama administration's decision to delay by two months, until March 31, the deadline for employees to furnish 1095-C forms to workers. The administration also delayed by three months, until June 30, the deadline for employees to transmit 1094-C and 1095-C forms to the IRS.
Elliott said the concerns were warranted, because the requirement is new for employers this year, and because the information they have to collect first "is much more involved" than just pulling workers' names and Social Security numbers.