Compliance Alert | ACA Reporting Obligations, Deadlines & Updates

Compliance Alert | ACA Reporting Obligations, Deadlines & Updates

January 14, 2025

Do you have a plan for meeting your ACA Reporting obligation?  At a time when IRS ACA penalties are increasing, paper filing is disappearing and submissions are getting more complex, the urgency for timely and compliant filing is more important than ever.

ACA Reporting Services

Do you have a plan for meeting your ACA Reporting obligation? Brinson offers ACA Reporting Services and the filing season is already in full swing! Please contact your Account Executive/Entrepreneur if you have questions about your reporting obligation or if you would like to use Brinson’s ACA Reporting Services. We are able to accept new clients up to January 31, 2025.

ACA Reporting Obligations

Applicable employers have a requirement to report to the IRS and their employees about their medical benefit offerings. The following employers are required to report on their 2023 calendar year medical benefit offerings:

  • Applicable Large Employers (ALEs) who averaged 50 or more full-time or full-time equivalent employees (FTE) during at least half of the 2022 calendar year
  • Employers who offered a self-funded or level-funded medical plan in the 2024 calendar year

ACA Reporting Deadlines

  • Form distribution to employees: March 3, 2025
  • Electronic Filing to the IRS: March 31, 2025

ACA Reporting Updates

  • Two bills were signed into law in December 2024 to ease the ACA Reporting Requirements for employers: 
    • The Employer Reporting Improvement Act includes several key provisions: 
      • Employers have the option to provide coverage notices electronically, streamlining the process.
      • Employee birthdates may be used in place of Social Security numbers when the latter are unavailable.
      • The time frame for employers to respond to IRS warning letters regarding health insurance reporting failures has been extended from 30 days to 90 days.
      • The Act imposes a six-year limitation on the IRS’s ability to collect assessments related to health benefits reporting failures, offering some protection for employers from long-term penalties.
    • The Paperwork Burden Reduction Act addresses the reporting of Forms 1095-B. Previously, employers were required to send these forms to all employees, and the IRS permitted employers to make the forms available only upon request. The new law codifies this approach, easing the paperwork burden on employers. Furthermore, the bill allows employers to apply the same approach to Form 1095-C, meaning these forms can be provided only when employees request them, rather than being automatically distributed to all employees.

After consulting with legal experts and other industry professionals, our ACA Reporting vendor partner has developed what we believe is the most prudent approach for our clients regarding 2024 filings—specifically, the decision on whether to mail forms. From our perspective, the timing of the law’s passage—so late in the ACA filing season—presents significant challenges, particularly from an HR communication standpoint. A key aspect of the new requirement is that employers must provide individuals with timely notice of their right to request the form, in accordance with any guidelines issued by the IRS. Additionally, employees have grown accustomed to receiving this form, which means upfront communication will likely be needed to manage expectations. Depending on the volume of forms requested, manually distributing them could also become a significant administrative burden. Furthermore, for employers with employees in states that have their own filing requirements, there is uncertainty about how the federal law aligns with state regulations.  For these reasons, we recommend waiting until the 2025 reporting season before deciding to discontinue printing forms.

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