ACA Disclosures Simplified; Guidance Issued

At the end of 2024, the Paperwork Burden Reduction Act became law. This law aims to ease the reporting burden and make changes to requirements related to Forms 1095-B and 1095-C. For additional information, see our January Benefit Beat article here. Recently, the IRS issued Notice 2025-15, the first piece of guidance related to this new law. According to this guidance, the law provides that the minimum essential coverage and the employer shared responsibility statements to individuals, the 1095-B or 1095-C, no longer need to be automatically distributed to individuals. The statement must be provided only if it is requested. To take advantage of this simplified disclosure process, employers and plan sponsors must:

• Provide a notice of availability of these forms that includes the following information:
  • a statement that a copy of the applicable form is available upon request;
  • an email address and physical address to submit the request; and
  • a telephone number.
• The notice must be posted in a location on the employer’s/plan sponsor’s website that is readily accessible for individuals entitled to the statements.
• Post the notice by the due date for furnishing the statements to individuals, including the automatic 30-day extension, March 3, 2025, for this year.
• The notice must remain on the applicable website until October 15 following the calendar year for which the statement was issued.

If an individual requests a 1095-B or 1095-C it must be provided within 30 days of the request or by January 31, whichever is later. The guidance affirms that the statement can be provided to the individual electronically. Importantly this simplified ACA disclosure option does not change the obligation to prepare and file the 1094 and 1095-B and C with the IRS. This is the first, but likely not the last, piece of ACA guidance from the current administration. This guidance may be coming to late for this year, but likely will be useful in the future.

The information contained in this Benefit Beat is not intended to be legal, accounting, or other professional advice, nor are these comments directed to specific situations. This information is provided as general guidance and may be affected by changes in law or regulation. This information is not intended to replace or substitute for accounting or other professional advice. You must consult your own attorney or tax advisor for assistance in specific situations. This information is provided as-is, with no warranties of any kind. CBIZ shall not be liable for any damages whatsoever in connection with its use and assumes no obligation to inform the reader of any changes in laws or other factors that could affect the information contained herein.