IRS Has Virtually Eliminated the Paper Filing Option
In February of 2023, IRS issued final regulations that lowered the threshold for when electronic filing is required (from 250 forms to 10 forms) and changed how the number of forms is determined. Previously, the 250-form threshold is measured by counting only Forms 1095-B. Now, the 10-form threshold counts all information returns, including Forms W-2 and Form 1095-C. Put the two together, and the result is that almost all employers are required to file electronically.
ACA Reporting Basics
Most employers find themselves subject to 1095 reporting because they are big enough to trigger the employer mandate, but that’s not the only way. The Affordable Care Act (ACA) also requires that all employers sponsoring self-insured health coverage, regardless of size, must report on which employees are covered by that health coverage— i.e., enrollment. Small employers with self-insured medical coverage are not required to report offers of coverage—i.e., eligibility.
There are two components to employer reporting:
Data filed with IRS: Employer data must be translated into the necessary 1095 codes. The coverage coding is complicated, and IRS is constantly tinkering with it, so it’s worth considering outsourcing this headache. The deadline to file the previous calendar year’s coverage with the IRS is February 28 (paper filers) or March 31 (electronic filers).
Individual information statements furnished to employees: Form 1095-B employee information statements tell employees (and the IRS) about health plan coverage on a month-by-month basis. Effective 2025, employers are no longer required to distribute 1095-Bs. Instead, they must be provided upon request. To take advantage of this rule, employers must:
Post a notice of availability that is “clear, conspicuous and accessible.” IRS has not yet issued guidance as to how and when the notice should be distributed.
Upon receipt of an employee request, distribute the form within 30 days or by January 31, whichever is later. With consent, electronic distribution is permitted.
ERISAfire Can Help
Normally, once you assemble your data, you have to analyze it, figure out the correct codes, fill out spreadsheet templates, audit your results, and respond to employee requests for forms.
How many of these steps do you have to do if you engage ERISAfire? None. ERISAfire takes the full burden of ACA reporting off of your shoulders.
No number crunching! All you have to do is provide readily available reports. ERISAfire will translate all that data into the necessary 1095 codes.
Complimentary compliance audit. We'll audit data output and identify potential 4980H penalty exposure. ERISAfire’s audit also covers process consulting to improve reporting outcomes and reduce costs next year.
Set it and forget it. We'll e-file your Forms 1094 and 1095 with the IRS as well as print and mail Forms 1095 to your employees.
Certified results. Your Forms 1094 and 1095 are reviewed by an experienced ERISA attorney prior to submittal to the IRS. Through our partnership with LeFevre Law PC, we will also defend our work should you be audited.