When Are ACA Due Dates? Deadlines for Taxes & Enrollment

The Affordable Care Act (ACA) established various provisions for health insurance coverage and reporting. Understanding ACA due dates is important for individuals seeking coverage and for entities reporting information to the government. These deadlines cover activities from individual tax filings to employer and health insurance provider reporting.

Individual Reporting and Tax Implications

Individuals are primarily concerned with how their health coverage impacts federal income tax returns. While the federal individual mandate penalty was reduced to zero after 2018, some states still impose their own health insurance mandates. Residents in these states may need to maintain minimum essential coverage or qualify for an exemption to avoid state-level penalties.

Individuals receive forms detailing their health coverage for tax filing. Form 1095-A, the Health Insurance Marketplace Statement, is issued to those who enrolled through a Health Insurance Marketplace. This form provides information to reconcile advance premium tax credit payments or claim the premium tax credit using Form 8962. Individuals typically receive Form 1095-A by January 31st of the year following coverage.

Form 1095-B, Health Coverage, and Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, also detail health coverage. Health insurance providers send Form 1095-B for coverage obtained outside the Marketplace, including through small employers or government programs. Applicable Large Employers (ALEs) issue Form 1095-C to their full-time employees, regardless of enrollment. Individuals typically receive Forms 1095-B and 1095-C by early March of the year following coverage.

These forms are informational and do not need to be attached to the tax return. The information helps individuals verify coverage and, if applicable, calculate any premium tax credit. Individuals must account for health coverage when filing their annual income tax return by the standard tax filing deadline, typically April 15th. If an error is found on Form 1095-A, contact the Marketplace immediately for a corrected form.

Employer and Provider Information Reporting Deadlines

Entities have specific deadlines for reporting health coverage information to the IRS and furnishing statements to individuals. Health Insurance Marketplaces must file Form 1095-A with the IRS and provide it to individuals by January 31st of the year following coverage.

Health insurance issuers and other providers of minimum essential coverage, including small employers with self-funded plans, must file Form 1095-B with the IRS. Applicable Large Employers (ALEs), those with 50 or more full-time equivalent employees, must file Form 1095-C with the IRS and furnish a copy to each full-time employee.

The deadline for furnishing Forms 1095-B and 1095-C to individuals is permanently extended by 30 days, making the due date March 2nd (or March 3rd in a leap year) for the previous tax year. For calendar year 2024 forms, this means they must be furnished by March 3, 2025. For filing with the IRS, deadlines are February 28th for paper filings and March 31st for electronic filings.

Employers and other reporting entities can request an automatic 30-day extension to file Forms 1095-B and 1095-C with the IRS by submitting Form 8809. This extension allows additional time to submit forms to the IRS but does not extend the deadline for furnishing copies to individuals. Penalties may apply for failure to file or furnish these forms by the specified deadlines.

Health Insurance Marketplace Enrollment Periods

Individuals enrolling in health insurance through the Health Insurance Marketplace have specific enrollment periods. The primary period is the Open Enrollment Period (OEP), typically from November 1st to January 15th annually for coverage beginning the following year. For 2025 coverage, OEP runs from November 1, 2024, to January 15, 2025. Enrolling by December 15th usually ensures coverage starts January 1st; later enrollment by January 15th typically results in coverage beginning February 1st.

Outside of OEP, individuals may qualify for a Special Enrollment Period (SEP). A SEP allows Marketplace enrollment due to a qualifying life event. Common events include losing health coverage, getting married, having a baby, adopting a child, or a permanent move to a new area with different health plans.

Individuals generally have a 60-day window following a qualifying life event to enroll through a SEP, starting on the event date. Specific effective dates for SEP coverage can vary, but often coverage begins on the first day of the month following plan selection. If an individual misses OEP and does not qualify for a SEP, they must generally wait until the next OEP to secure Marketplace coverage.