Compliance Alert | ACA Reporting Updates, Obligations & Deadlines
January 18, 2024
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 Updates
Please review the following updates from the last year for changes that may affect you this filing season.
- Employers with less than 250 total 1095-C forms have had the option to file with the IRS utilizing paper forms. Starting in 2024 (for reporting on the 2023 calendar year), only employers with 10 or fewer 1095-C forms can take advantage of the paper filing option. All other employers need to be prepared to file their forms electronically.
- Employers have had a requirement to furnish individual statements to their employees by January 31 of the year following the year being reported. Starting in 2023 (for reporting on the 2022 calendar year), the deadline for furnishing statements to employees was permanently extended by 30 days. Additionally, employers with employees in one of the states that require filing (CA, DC, NJ, RI, VT) need to be prepared to meet the deadlines specific to the state which may differ from the IRS deadlines.
- Employers have had the benefit of the IRS offering good faith transitional relief for ACA reporting and filing mistakes. Starting in 2023 (for reporting on the 2022 calendar year), the IRS formally declined to extend that relief. Additionally, starting in 2024 (for reporting on the 2023 calendar year), employers that fail to file their forms can be subject to a $310 penalty per form. The updated penalty for failure to provide individual statements to employees also will increase to $310 per statement. Since the penalties are cumulative, an employer that fails to provide an employee statement and fails to file with the IRS can be penalized up to $620 for each required form. Employers need to take great care to ensure the timely and accurate filing and distribution of their forms.
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 2021 calendar year
- Employers who offered a self-funded or level-funded medical plan in the 2023 calendar year
ACA Reporting Deadlines
- Form distribution to employees: March 2, 2024
- Electronic Filing to the IRS: March 31, 2024
If you have questions, your Brinson Account Executive can help!
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