At the end of 2024, Conner Strong & Buckelew provided an Update on new Affordable Care Act (ACA) employer reporting changes signed into law. While the new rules did not significantly change existing employer reporting requirements, they did allow employers to meet Form 1095 distribution requirements for the 2024 reporting year by posting a notice of availability and then only distributing the Form upon request. We promised to provide an update on any subsequent IRS guidance on the notice requirements for the new distribution methods. The IRS has now released guidance providing further detail on how to satisfy the notice requirement and confirming that such notice must be posted by March 3, 2025, for the 2024 reporting year.
We have seen some employers not yet taking advantage of the alternative as they have already had their vendor mail the Forms for the 2024 year. However, we will likely see many more take advantage of this alternative next year. For any employer looking to provide the 1095-C by request, we can confirm IRS guidance Notice 2025-15 provides this is a viable option as long as the employer does the following:
A clear and conspicuous notice must be posted on a website that is reasonably accessible to all possible Form 1095 recipients.
For the 2024 reporting year, the notice must be posted by March 3, 2025 and remain in the same location on the website through October 15, 2025.
The notice must include an email address, physical address, and telephone number that can be used to request a copy of Form 1095.
If after posting notice of availability the employer receives a request for a Form 1095, the Form 1095 must be provided within 30 days and would have to be hand delivered or mailed.
Electronic distribution is permitted if employee consents (which is valid until withdrawn in writing).
Note that employers must still prepare and file Forms 1095-C with the IRS each year (generally due to be filed with Form 1094-C transmittal form by March 31). And for employers subject to state-level reporting requirements in CA, MA, NJ, RI, or DC, note too that this relief for distribution of Form 1095s may not be available.
The IRS did not provide a model notice in this most recent guidance, but here is a sample to consider for posting:
MODEL / SAMPLE NOTICE
IMPORTANT HEALTH COVERAGE – TAX DOCUMENTS
Form 1095-C, titled Employer-Provided Health Insurance Offer and Coverage, is a statement of health coverage offered to eligible employees. These Forms have previously been automatically electronically distributed/mailed in prior years. According to the Internal Revenue Service (IRS), an individual does not need the information on Form 1095-C to file income taxes with the IRS. Therefore, the IRS is now allowing reporting entities to furnish 1095-C forms only upon request. Please review below for instructions on how to elect to receive the Form 1095-C.
Electing to Receive 1095-C Form Electronically
Employees should follow the below steps to consent to the electronic delivery of their 1095-C forms for the current tax year and thereafter:
CLICK HERE to log in to __.
From the home page, click on ___.
Select “1095-C Printing/Electronic Distribution Election” for your current and future 1095-C forms.
Once you have made your selection, click OK & Done.
Electing to Receive 1095-C Form by Mail
If you would like to receive your Form 1095-C for the 2024 tax year by mail, please submit your request using one of these options:
Calling this number: ______________________
Sending an email request to: ______________
Sending a regular mail request to: ___________
Include your name, a phone number and email address where you can be reached, and confirm your mailing address to request your 1095-C.
To learn more about this Form 1095-C and other Affordable Care Act (ACA) requirements, please visit IRS.gov/aca or call the IRS at (800) 829-1040.
Employers can choose to implement these changes in order to streamline some of their ACA reporting processes and reduce certain administrative burdens. Contact ACA reporting vendors regarding these reporting-related changes to determine how they will provide support with these optional reporting opportunities for the 2024 ACA reporting season. Should you have questions, contact your Conner Strong & Buckelew account representative toll-free at 1-877-861-3220. For a complete list of Legislative Updates issued by Conner Strong & Buckelew, visit our online Resource Center.
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