When Is ACA Reporting Due? Key Deadlines
Understand the essential deadlines for Affordable Care Act (ACA) reporting to ensure timely compliance and avoid penalties.
The Affordable Care Act (ACA) established reporting requirements for certain entities to provide information about health coverage. This reporting helps demonstrate compliance with the ACA’s provisions, particularly concerning health coverage offers and enrollment. Entities must collect and submit specific data to the Internal Revenue Service (IRS) and furnish statements to individuals, ensuring transparency and adherence to the law.
Identifying Reporting Responsibilities
ACA reporting responsibilities involve several classifications. Applicable Large Employers (ALEs) are a primary focus, defined as employers with 50 or more full-time equivalent employees in the prior calendar year. An employer’s ALE status is determined annually based on the average size of its workforce from the preceding year, triggering obligations related to employer shared responsibility provisions.
Other entities also have reporting duties. Employers of any size must report if they offer self-insured health coverage. Health insurance issuers and government agencies providing minimum essential coverage are also required to report.
Understanding Required Data
ACA reporting mandates the collection of specific information, which is then submitted on designated IRS forms. Applicable Large Employers (ALEs) primarily use Forms 1095-C and 1094-C. Form 1095-C details offers of health coverage and enrollment for each full-time employee, including data points such as the offer of coverage, the employee’s share of the premium, and applicable safe harbor codes. Form 1094-C serves as the transmittal form, summarizing the ALE’s overall filing and providing aggregate employer-level data to the IRS.
Other reporting entities, such as non-ALEs with self-insured health plans and health insurance providers, use Forms 1095-B and 1094-B. Form 1095-B reports minimum essential coverage provided to individuals, detailing covered individuals and months of coverage. Form 1094-B acts as the transmittal form for the 1095-B submissions. The information on these forms allows the IRS to verify compliance and administer various aspects of the ACA, including eligibility for premium tax credits.
Key Reporting Deadlines
Meeting specific deadlines is an important aspect of ACA reporting. For the 2024 tax year, employers must furnish Forms 1095-C or 1095-B to employees and responsible individuals by March 3, 2025. This deadline includes an automatic 30-day extension from the traditional January 31 due date.
Filing these forms with the IRS involves different deadlines based on the submission method. For paper filing of Forms 1094-C/1095-C and 1094-B/1095-B for the 2024 tax year, the deadline is February 28, 2025. If filing electronically, the deadline extends to March 31, 2025. If any of these due dates fall on a weekend or legal holiday, the deadline shifts to the next business day. Employers can request a 30-day extension to file with the IRS by submitting Form 8809 by the original due date.
Submission Procedures and Non-Compliance Outcomes
Submitting ACA forms to the IRS can be done either electronically or via paper, depending on the volume of returns. Employers filing 10 or more information returns, including Forms 1094-C, 1095-C, 1095-B, W-2s, and 1099s, are generally required to file electronically. Electronic filing is conducted through the IRS’s Affordable Care Act Information Returns (AIR) program, which requires prior registration and a Transmitter Control Code (TCC). This system is encouraged even for those filing fewer than 10 returns.
For those permitted to file on paper, typically employers with fewer than 10 total information returns, the forms are mailed directly to the IRS. Failing to comply with ACA reporting requirements can result in penalties. Penalties may apply for failing to file on time, failing to furnish statements to individuals on time, or filing incorrect or incomplete information. For the 2024 tax year, penalties for failing to file or provide a correct statement are $330 per return or statement. These penalties can escalate, emphasizing the importance of accurate and timely reporting.