The Paperwork Burden Reduction Act (HR 3797) and Employer Reporting Improvement Act (HR 3801) were signed into law in the final days of 2024. Of importance, the Paperwork Burden Reduction Act now allows employers to furnish 1095-C forms to applicable members only when requested by the member, as long as the employer posts a notice prominently on their website. Previously, most 1095-C forms were required to be furnished annually to applicable members.
Under this alternative furnishing option, the employer must furnish the forms by January 31 or within 30 days of the request, whichever is later. Please note that the January 31st deadline is earlier than the current form furnishing deadline, which was permanently extended to 30 days after January 31st (or the following Monday, when that day falls on a weekend).
Please note that other than this alternative form furnishing option, the majority of ACA reporting remains unchanged – the details and rules around ACA reporting remain incredibly complex and are outside the scope of this update.
Important reminders:
Electronic Filing:
- The electronic filing (e-filing) deadline remains 3/31 (or the Monday following) for all 1094/1095 forms,
- Electronically filing forms requires creating an XML file with the applicable reporting data and obtaining the necessary IRS AIR credentials to file with the IRS,
- Any entity filing more than 10 forms each year must file electronically (this threshold was previously 250 forms, reduced to 10 in 2023).
ACA Rules & Regulations:
- Determining who is due a form, the ACA full-time status of employees, and the subsequent codes follows strict rules outlined by the ACA – understanding these rules and regulations can be one of the biggest challenges when preparing forms annually,
- The IRS discontinued the “good faith” relief efforts starting with the 2021 filings – employers may face a per form penalty for inaccurate or incomplete filings.
State/District Level Reporting:
- California, New Jersey, Rhode Island, Vermont, and Washington D.C. have enacted special reporting requirements since the inception of the ACA – these can include different deadlines and filing formats compared to the federal requirements.
Conrad Siegel & ACA Reporting:
With more options available for furnishing and continued complexity and scrutiny of these forms, we encourage all employers to review their ACA reporting process heading into the 2025 reporting season. Conrad Siegel is available to answer questions or assist groups with their ACA reporting process. We take the time to thoroughly review and analyze the data provided to ensure proper reporting to help limit potential penalties for inaccurate or incomplete filings to the IRS – without significant input needed from you and your team. Please feel free to direct any questions regarding ACA Reporting to our