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This article serves as a reminder for ACA Reporting Deadlines imposed on Applicable Large Employers (ALEs) and certain non-ALEs that sponsor self-insured medical plans.

There are two components to the ACA reporting requirements.

1. ALEs must furnish individual statements, generally 1095-Cs, to full-time employees by March 3, 2025
   • Non-ALEs who sponsor a self-insured plan must furnish 1095-B forms to employees by the same date.
2. ALEs must report 1094C and 1095C information to the IRS by March 31, 2025, if filing electronically
   • Non-ALEs who sponsor a self-insured plan must report 1094&5-B forms to the IRS by the same date.

IMA Special Announcement: Currently, there are two bills awaiting the President’s signature that would simplify the reporting process for employers, including alleviating the burden of automatically distributing 1095-B&C forms to individuals. More information can be found here. We will keep our readers updated as soon as the bills are signed into law.

Penalties for inaccurate, incomplete or absence of reporting: The IRS made it clear that “good faith relief” is no longer available which means employers must be diligent with regards to inaccurate or incomplete forms.

For 2024 reporting due in 2025, the IRS may impose penalties of up to $330 per form for providing a participant with inaccurate or incomplete forms. A separate $330 per form penalty could be applied for the same mistake in the forms filed with the IRS, potentially triggering a penalty of up to $660 per employee.

There is also state-level reporting of such forms that were introduced via individual coverage mandates in certain states.

For more information regarding state level reporting for employers with CA, MA, NJ, RI and D.C. workers, please contact your IMA representative.

IMA will continue to monitor regulator guidance and offer meaningful, practical, timely information. This material should not be considered as a substitute for legal, tax and/or actuarial advice. Contact the appropriate professional counsel for such matters. These materials are not exhaustive and are subject to possible changes in applicable laws, rules, and regulations and their interpretations.

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