Q: As the 2024 calendar year comes to an end, what are the requirements for Affordable Care Act reporting that are due in 2025?
A: The Affordable Care Act has reporting requirements for;
- Applicable Large Employers,(ALE), defined as employers with 50 or more full-time equivalent employees in the prior calendar year; must report using IRC Form 6056. The report tells the IRS they offered affordable medical coverage that provides minimum essential coverage to full-time employees and their dependents as required by the ACA.
- Small employers who offer employees a self-funded health plan, level funded plan, or Individual Coverage Health Reimbursement Account (ICHRA) will report with IRC Form 6055. The report tells the IRS the employer has provided minimum essential coverage to the individuals covered under their health plan.
The 2024 forms for 6055-6056 reporting did not have any material changes. Employers required to file the forms should note the following:
- Employers must file electronically if they have 10 or more information returns. Reporting entities must aggregate most information returns, such as Forms W-2, 1099, 1094-C, and 1095-C, to determine if the 10 returns threshold for electronic filing is met.
- Forms must be distributed to employees on or by March 3, 2025.
- If you are filing electronically, the deadline for filing is March 31, 2025. Paper forms are due February 28, 2025.
All ALE’s are also required to file forms 1094-C and 1095-C to fulfill the 6056 reporting. These forms fulfill the employers 6056 reporting as well as the 6055-reporting requirement. The forms did not change from last year. The 2024 Instructions for Forms 1094-C and 1095-C include the codes to use and filing requirements. If an ALE offers a self-insured plan, level-funded plan or Individual Coverage Health Reimbursement Account (ICHRA), they must complete Part III of form 1095-C to fulfill the 6055-reporting requirement. As a reminder, an ALE is defined generally as an employer who has 50 or more Full-Time Equivalent Employees in the prior calendar year.
Small employers who offer a self-insured plan, level-funded plan or an ICHRA, must report the 6055 requirement using forms 1094-B and 1095-B. As stated on page 5 of the 2024 Instructions for Forms 1094-B and 1095-B, a small employer is not required to distribute the forms to employees as long as the employer post prominently posts a notice on its website stating that responsible individuals may receive a copy of their 2023 Form 1095-B upon request, accompanied by an email address and a physical address the statement can be sent address to which a request may be sent, as well as a telephone number that responsible individuals can use to contact the reporting entity.
To learn more about how Liberty Insurance Agency can help protect your business and employees, contact us at 412-571-5700.
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