March 12, 2025

Following the passage of the Employer Reporting Improvement Act (H.R. 3801 / S. 3204) and the Paperwork Burden Reduction Act (H.R. 3797 / S. 3202) at the end of 2024, the IRS has released Notice 2025-15, clarifying how large employer plan sponsors can utilize new reporting flexibilities under Sections 6055 and 6056 of the Affordable Care Act (ACA).

The ACA established employer reporting requirements to ensure compliance with the Employer Shared Responsibility provisions under Section 4980H and individual health coverage reporting under Section 6055 and to facilitate eligibility determinations for premium tax credits and cost-sharing reductions under Section 6056. These requirements mandate applicable large employers (ALEs) to report information about health coverage offered to employees and their dependents generally via IRS Forms 1094-C and 1095-C.

The Paperwork Burden Reduction Act specifically introduced a new, permanent alternative to furnishing statements to individuals, allowing employers and insurers to satisfy their obligation by posting a clear and conspicuous notice online stating that individuals may request a copy of their statement.

The new IRS guidance clarifies how ALEs can use the alternative furnishing method and sets compliance expectations for 2024 and beyond. According to Notice 2025-15, this online notice must have been made available by March 3, 2025, to align with the extended deadline for providing 2024 statements. If an employee requests a statement, the employer must provide it within 30 days of the request or by January 31 of the following year (whichever is later).

Additionally, while previous regulations focused on insurers and Form 1095-B, the Notice confirms that ALEs can rely on the same method by substituting the term “full-time employee” for “responsible individual” and the term “Form 1095-C, Employer-Provided Health Insurance Offer and Coverage” for “Form 1095-B, Health Coverage.”

This notice is effective for statements required by Section 6055 or Section 6056 with respect to returns for calendar years after 2023.

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Resource Affordable Care Act (ACA) Compliance