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2025 New Legislation: Impact on ACA Employer Reporting
Two new bills impacting the ACA employer reporting requirements under Sections 6055 and 6056 have been signed into law by President Biden, and they will be effective for the 2024 Reporting Year. These changes are designed to streamline the reporting process for employers.
Key Updates:
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Form 1095 Distribution Requirements (Effective for the 2024 Reporting Year):
Employers are no longer required to automatically distribute Form 1095-C or 1095-B to individuals to meet distribution requirements. Instead, employers must take the following actions:
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Post a notice that is “clear, conspicuous, and accessible” with additional guidance to be provided on how to fulfill this notice requirement.
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Distribute the forms upon request by the individual, no later than March 3rd or 30 days after the request.
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Reporting for Self-Funded Plans (Effective for the 2024 Reporting Year):
Employers reporting self-funded group health plan coverage for spouses and dependents may now use the individual’s date of birth in place of the tax identification number (TIN) when the TIN is unavailable. This adjustment removes the prior requirement to establish reasonable cause before utilizing the date of birth.
ACA Overview of Reporting Rules:
Attached below is an ACA Compliance Overview document summarizing the reporting rules under Code Sections 6055 and 6056. This is a valuable guide that includes relevant requirements, deadlines, resources and more.
Click below to download the overview:
Employer Reporting of Health Coverage Code Sections 6055 and 6056
The table below is a brief overview of some key reporting guidelines.
6055/6056 Reporting Guidelines
| 6055 (Reporting by Health Coverage Providers) |
6056 (Reporting Offers of Health Insurance by Employers) |
|
|---|---|---|
| All health insurance plan issuers (insurance company) and all employer plan sponsors that provide health coverage. | Employers with an average of 50 or more full-time employees including full-time equivalent employees during the preceding calendar year. | |
| Reported By |
Fully Insured Plans: The insurance company responsible Self-Funded and Level-Funded Plans for Non-ALE Employers: Employer responsible |
Fully Insured Plans, Self-Funded, and Level-Funded Plans for ALE Employers: Employer responsible Click below for assistance determining your ALE status: |
| 2024 Required Forms | Form 1095-B Form 1094-B |
Form 1095-C Form 1094-C |
| Form Instructions | 2024 Instructions for Forms 1094-B and 1095-B (irs.gov) | 2024 Instructions for Forms 1094-C and 1095-C (irs.gov) |
| Reporting Deadlines | Feb 28, 2025 – to IRS if an employer is reporting on paper (available for groups of 9 or less)
March 31, 2025 – to IRS if an employer is reporting electronically (required for groups of 10 or more) |
Feb 28, 2025 – to IRS if an employer is reporting on paper (available for groups of 9 or less)
March 31, 2025 – to IRS if an employer is reporting electronically (required for groups of 10 or more) |
The tables below are designed to help employers understand what their reporting responsibilities are, under IRC Section 6055 and/or IRC Section 6056.
The tables only show group sizes and the types of coverage funding arrangements, where employer reporting is required. If the tables do not include your group size or coverage funding arrangement, then you are not required to report.
Fully Insured Groups
CARRIER |
WHAT THE CARRIER PROVIDES |
WHAT THE EMPLOYER NEEDS TO DO |
|---|---|---|
| Blue Cross and Blue Shield of Minnesota |
BCBSMN will file 1095-Bs and 1094-Bs with the IRS Forms 1095-B are mailed to members |
N/A – Carrier Completes |
| Blue Cross and Blue Shield of Nebraska |
BCBSNE will file 1095-Bs and 1094-Bs with the IRS 1095-Bs are sent to members’ homes |
N/A – Carrier Completes |
| HealthPartners of Minnesota |
HealthPartners will file1095-Bs and 1094-Bs with the IRS Members can request 1095-Bs from HealthPartners by contacting Member Services at 952-883-5000 |
N/A – Carrier Completes |
| Medica |
Medica will file 1095-Bs and 1094-Bs with the IRS Forms 1095-B are available to members upon request. Requests can be made one of the following ways: Phone: Calling the number on the back of their ID card Email: askmedica@medica.com (not secure, recommended to not include any PHI) Online: Submitting the Contact Form found on medica.com |
N/A – Carrier Completes |
| UnitedHealthcare |
UHC will file 1095-Bs and 1094-Bs with the IRS 1095-Bs are sent to members |
N/A – Carrier Completes |
Self-Funded & Level-Funded Groups (1-49)
CARRIER |
WHAT THE CARRIER PROVIDES |
WHAT THE EMPLOYER NEEDS TO DO |
|---|---|---|
| Aetna |
Aetna will file 1095-Bs and 1094-Bs with the IRS on behalf of groups Members can pull the reports directly from the member portal |
N/A – Carrier Completes |
| Allstate | Notifications are sent via email to employers |
File 1095-Bs and 1094-Bs with the IRS; Send 1095-Bs to members upon request Allstate will load group data into the CXC Solutions portal, so employers will just need to verify the information is accurate before filing with the IRS and generating the forms |
| Blue Cross and Blue Shield of Nebraska | OCI will send over a member report from BlueCross BlueShield | File 1095-Bs and 1094-Bs with the IRS; Send 1095-Bs to members upon request |
| HealthPartners of Minnesota | Members can request 1095-Bs from HealthPartners by contacting Member Services at 952-883-5000 | File 1095-Bs and 1094-Bs with the IRS |
| Medica |
Reports are available to employers upon request. Requests can be made one of the following ways: Phone: Calling the number on the back of their ID card Email: askmedica@medica.com (not secure, recommended to not include any PHI) Online: Submitting the Contact Form found on medica.com |
File 1095-Bs and 1094-Bs with the IRS; Send 1095-Bs to members upon request |
| UnitedHealthcare |
1095-Bs and 1094-Bs are available in Mineral. Employers must log in to their Mineral portal to access these forms and complete ACA reporting An instruction guide is attached below: |
File 1095-Bs and 1094-Bs with the IRS; Send 1095-Bs to members upon request |
Applicable Large Employer Groups
(Fully Insured & Self-Funded)
CARRIER |
WHAT THE CARRIER PROVIDES |
WHAT THE EMPLOYER NEEDS TO DO |
|---|---|---|
| Aetna | Employers can pull the reports directly from the Employer Portal | File 1095-Cs and 1094-Cs with the IRS; Send 1095-Cs to members upon request |
| Allstate | Notifications are sent via email to employers |
File 1095-Cs and 1094-Cs with the IRS; Send 1095-Cs to members upon request Employers have two options to complete their filing: 1. CXC Solutions (Allstate Benefits’ ACA compliance vendor) will provide an online portal to complete ACA reporting, provide forms to employees, and e-file with the IRS at no charge 2. File manually |
| Blue Cross and Blue Shield of Nebraska | OCI will send over a member report from BlueCross BlueShield | File 1095-Cs and 1094-Cs with the IRS; Send 1095-Cs to members upon request |
| HealthPartners of Minnesota | Employers can pull the report directly from the Employer Portal | File 1095-Cs and 1094-Cs with the IRS; Send 1095-Cs to members upon request |
| Medica |
Reports are available to employers upon request. Requests can be made one of the following ways: Phone: Calling the number on the back of their ID card Email: askmedica@medica.com (not secure, recommended to not include any PHI) Online: Submitting the Contact Form found on medica.com |
File 1095-Cs and 1094-Cs with the IRS; Send 1095-Cs to members upon request |
| UnitedHealthcare |
Employers can pull the reports directly from the Employer Portal |
File 1095-Cs and 1094-Cs with the IRS; Send 1095-Cs to members upon request |
