As we move into the second quarter of 2025, employers need to be aware of important deadlines for ACA reporting requirements. The Affordable Care Act (ACA) mandates that Applicable Large Employers (ALEs) AND businesses who are level-funded or self-funded, regardless of company size must file Forms 1094-C and 1095-C to report health coverage information to the IRS. Here’s what you need to know to stay compliant.
Key Deadlines
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Furnishing Forms to Employees:
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March 3, 2025: Employers must furnish Form 1095-C to eligible employees. This form provides details about the health coverage offered to employees throughout the year. If you’ve not done it, get on it!!
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Filing with the IRS:
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February 28, 2025: Deadline for filing paper Forms 1094-C and 1095-C with the IRS – This deadline has passed!
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March 31, 2025: Deadline for electronic filing of Forms 1094-C and 1095-C – If you’ve not done this, there are lots of resources out there. We’ll list some at the end of the article.
Changes to Reporting Requirements
Starting in 2025, there are notable changes to the ACA reporting requirements that aim to simplify the process for employers:
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Form Distribution: Employers are no longer required to distribute Form 1095-C to all full-time employees unless requested. Instead, they must post a notice of availability on their website by March 2 each year
This notice must be clear, conspicuous, and accessible, stating that Form 1095-C is available upon request
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Self-Insured Plans: For self-insured plans, employers can now use the individual’s full name and date of birth if their social security number (SSN) or taxpayer identification number (TIN) cannot be obtained. This change eases the burden on employers who have experienced difficulties obtaining the necessary TIN from nonresident aliens.
Preparing for Compliance
To ensure compliance with these deadlines and changes, employers should do the following:
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Review Reporting Requirements: Familiarize yourself with the updated ACA reporting requirements and deadlines.
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Post Notice of Availability: Ensure the notice of availability for Form 1095-C is posted on your website by March 2, 2025.
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Gather Necessary Information: Collect and verify the required information for Forms 1094-C and 1095-C, including employee health coverage details.
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File Timely: Submit the forms to the IRS by the respective deadlines to avoid penalties.
Need help? Not sure what to do next but you’ve not e-filed? Here are some resources:
Here are a few resources we wanted to share in case you’ve NOT done your e-filings yet.
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If you have your forms ready you just need to submit them, here’s the link to the IRS page where you can go online and do your e-filing –
https://www.irs.gov/tax-professionals/affordable-care-act-aca-services
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If you’ve not completed your forms yet, there are a few resources available that you may not know about.
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Ask your CPA or payroll provider if this is something they can help with. Many can knock these forms out for you for a nominal fee, especially for smaller businesses. Most CPAs / payroll companies can also file for you which is nice.
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Online Enrollment System – If you are using an online enrollment system (we use Ease / Employee Navigator internally), there are often times tools in there that will produce these forms for you. Regardless of the system, most have some form of capabilities along these lines. Ask your POC or do some digging, any system that will produce these forms for you will save you a lot of time.
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If you are a UnitedHealthcare group health client, there’s a good chance you might have access to the Mineral (formerly ThinkHR) platform that UHC provides. If you do, you can produce ALL of the forms and e-file through that platform. This was new this year so we tested it on our own company and it was quite nice to be able to do everything, even the e-filing in one platform.
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Talk to your agent/broker (or H|BC). There are a lot of resources and vendors that will help with these items. Outside vendors / TPA’s will be the least affordable option but if you simply don’t have the time to do the forms internally and items a-c are not options, this is a better option than NOT filing and then later getting audited and penalized but the IRS or DOL.
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To Wrap Up
Staying on top of ACA reporting requirements is crucial for employers to avoid penalties and ensure compliance. The LAST thing you want is the IRS or DOL showing up at your workplace and asking to see your payroll and employee records. That is not ever fun. We hope that the above sheds some light on this nuanced reporting that is still required by the government and also provides some thoughts / good resources that you can take advantage of.
As always, if you would like to discuss any of the above, please let us know. We love to strategize and problem-solve!!! Thanks for the read,
Ryan
