Navigating the complexities of health insurance reporting can be daunting, especially with recent changes to the Affordable Care Act (ACA) requirements. One significant update is the option for employers to furnish Forms 1095-B and 1095-C to individuals only upon request.

What Are Forms 1095-B and 1095-C?

Forms 1095-B and 1095-C are essential documents related to health insurance coverage:

• Form 1095-B: This form is issued by health insurance providers, including employers who sponsor self-insured health plans, to individuals covered under their plans.
• Form 1095-C: This form is provided by Applicable Large Employers (ALEs) to their full-time employees, detailing the health insurance coverage offered.

What Is an Applicable Large Employer (ALE)?

An Applicable Large Employer (ALE) is an employer that had at least 50 full-time employees, including full-time equivalent employees, on average during the prior year. ALEs are subject to the employer shared responsibility provisions and the employer information reporting provisions under the ACA.

Furnished Upon Request

Recent legislation, including the Paperwork Burden Reduction Act and the Employer Reporting Improvement Act, has introduced a significant change: starting with the 2024 calendar year, employers are no longer required to automatically mail these forms to employees. Instead, they can provide them upon request.

How It Works

To comply with the new rules, employers must:

1. Provide Notice: Employers must inform employees that Forms 1095-Band 1095-C are available upon request. This notice should be clear, conspicuous, and accessible.
2. Respond to Requests: Upon receiving a request, employers must furnish the requested form within 30 days or by January 31 of the following year, whichever is later.
3. File with the IRS: Despite the change in distribution to employees, employers must still file these forms with the IRS along with the corresponding transmittal forms (1094-B and 1094-C).

Key Deadlines for 2025

• February 28, 2025: Deadline for filing paper Forms 1094-C and 1095-C with the IRS.
• March 3, 2025: Deadline for furnishing Forms 1095-B and 1095-C to employees.
• March 31, 2025: Deadline for electronic filing of Forms 1094-C and 1095-C with the IRS.

Steps for Employers

• Prepare Notices: Draft and distribute notices to employees about the availability of Forms 1095-B and 1095-C upon request.
• Set Up a Request System: Implement a system to manage and respond to employee requests for these forms efficiently.
• Ensure Compliance: Continue to prepare and submit the required forms to the IRS by the specified deadlines.

Staying informed about these changes ensures both employers and employees can navigate the ACA reporting requirements effectively.

Partnering with Pierce Group Benefits

At PGB, our team stays up to date on new regulations and their impact on our clients’ employee benefits. To understand how these changes affect your organization, contact your dedicated Pierce Group Benefits Account Executive or reach out to a PGB Representative at partnership@piercegroupbenefits.com for further information.