On February 21, 2025, the Internal Revenue Service (“IRS”) released Notice 2025-15, providing guidance to employers and insurers regarding the alternative manner of furnishing certain health insurance coverage statements to individuals under sections 6055(c)(3) and 6056(c)(3) of the Internal Revenue Code (the “Code”).
As context, applicable large employers (ALEs) and insurers that provide minimum essential coverage (MEC) must annually report information about each covered individual to the IRS and provide Forms 1095-B and 1095-C (documents showing proof of MEC). The Paperwork Burden Reduction Act permits employers and insurers to forgo automatically sending Forms 1095-B and 1095-C to individuals, provided that a timely notice is provided and individuals do not specifically request the forms.
The Notice clarifies that the existing alternative manner rule for furnishing statements to certain individuals (other than full-time employees) also applies to full-time employees. Specifically, employers or insurers must post a notice on their website that clearly and conspicuously informs individuals that they may request a copy of their forms. The notice must also include contact details such as an email address, physical address, and phone number for inquiries if individuals have questions. Additionally, such notice must be posted on the website by the due date for providing the statement, including any extensions.
