Under the ACA, employers and insurers must file information returns to report health coverage to the IRS and provide copies to employees. This typically involves:
- Form 1095-C: For ALEs (50+ full-time employees), reporting offer of coverage
- Form 1095-B: For small employers with self-insured plans or insurers reporting minimal essential coverage (MEC)
These forms must also be accompanied by transmittal Forms 1094-B or 1094-C when filed with the IRS.
What’s New Federally?
1. 10-Form E-Filing Threshold
As of tax year 2023 (filed in 2024), the IRS requires electronic filing if you file 10 or more information returns total — including Forms 1099, W-2, and ACA forms. Paper filing exceptions are now rare.
2. Elimination of Good-Faith Relief
Previously, filers could avoid penalties for incorrect/incomplete ACA forms if they showed good-faith efforts. Starting in tax year 2021, this relief was eliminated. Accuracy now matters more than ever.
3. Form 1095-B Relief for Insurers
The IRS continues to allow insurers and small self-insured employers to post a notice on their website instead of mailing 1095-B forms, if no individual request has been made. But you must provide the form upon request within 30 days.
