Laws enacted at the end of 2024 made important changes to the ACA reporting requirements. (Our previous alert regarding the ACA reporting changes can be found here.) The laws codified an alternative option for furnishing certain forms to individuals and authorized the IRS to issue new guidance on the ACA reporting requirements. Recently, the IRS issued this new guidance.
The new guidance reaffirms the applicability of existing regulations. To comply with the alternative option for furnishing Forms 1095-C and 1095-B to individuals, an employer must:
- Post a “clear and conspicuous” notice on its website.
- The notice must be in a location on the website that is reasonably accessible to all applicable individuals.
- The notice must state that the Form 1095-C or 1095-B, as applicable, is available upon request.
- The notice must include an email address, a physical address to which a request may be sent, and a telephone number that an individual may use to contact the employer for more information.
- The notice must be written in nontechnical terms and must call to the viewer’s attention that the information pertains to tax statements reporting that individuals had health coverage.
- The deadline for posting the notice is March 3, 2025. The notice must remain on the website until October 15, 2025.
- The employer must actually make the form available within 30 days of the request.
