Affordable Care Act Reporting Requirements
On December 17, 2024, the House Ways and Means Committee and the Senate Finance Committee presented two bills – the Paperwork Burden Reduction Act (HR 3797) and the Employer Reporting Improvement Act (HR 3801) – to President...more
On Monday, December 23, 2024, President Biden signed into law two bills, H.R. 3797 (the “Paperwork Reduction Act”) and H.R. 3801 (the “Employer Reporting Improvement Act”), which will positively impact applicable large...more
Congress recently passed the Employer Reporting Improvement Act and the Paperwork Burden Reduction Act (the Acts), which are now awaiting President Biden’s signature. The Acts, among other things, introduce several...more
The Internal Revenue Service (IRS) has released Rev. Proc. 2024-35, which contains the inflation adjusted amounts for 2025 used to determine whether employer-sponsored coverage is “affordable” for purposes of the Affordable...more
Nearly once a week, I receive a frantic call or email from a current or potential client who has received a proposed or final assessment from the IRS related to Affordable Care Act (“ACA”) reporting. So-called “Applicable...more
Gear up for another year of ACA reporting! Dive into a comprehensive 90-minute webinar led by Warner Norcross + Judd LLP attorney Stephanie Grant. Gain invaluable insights about the ACA reporting essentials, what codes to use...more
Since the inception of the annual reporting requirements under the Affordable Care Act for Forms 1094 and 1095, the IRS has been annually extending the deadline for employers to distribute those reports to individuals. In...more
Seyfarth Synopsis: Recently the U.S. Treasury Department (Treasury) and Internal Revenue Service (IRS) issued regulations (the “Final Regulations”) which finalized previously proposed relief for furnishing Forms 1095-B and...more
Applicable large employers must adhere to many Affordable Care Act (ACA) rules to remain compliant regarding group health plan offerings. We offer the following checklist of the five most helpful reminders you should take...more
For several years, the IRS showed leniency to large employers (50 or more employees) who failed to file Forms 1095-C and 1094-C accurately or by the annual deadline. The IRS has signaled these forms will be reviewed with...more
As we discussed in a prior article, it is now more important than ever for employers to ensure they fully and accurately complete IRS Forms 1094-C and 1095-C — forms required to be filed and/or furnished to employees under...more
The Internal Revenue Service (“IRS”) recently issued proposed regulations affecting certain reporting deadlines under the Patient Protection and Affordable Care Act (“ACA”). Specifically, proposed regulations would make...more
Seyfarth Synopsis: The IRS has released final instructions for completing Forms 1094-C and 1095-C for 2021. Notably the instructions provide that the due date for furnishing Form 1095-C to individuals is extended to March 2,...more
The Internal Revenue Service recently released a host of changes to Form 1095-C reporting required under the Affordable Care Act. This is welcome relief for large employers who struggle to deliver these forms to employees by...more
On November 22, 2021, the Department of Treasury and the IRS issued proposed regulations generally intended to provide Form 1095-B and 1095-C reporting relief. Under the statutory language of the ACA, reporting entities are...more
In a similar move as in previous years, the IRS has issued relief from certain Form 1094-C and 1095-C reporting requirements under the Affordable Care Act relating to employee health plans, as well as relief from certain...more
The Internal Revenue Service (IRS) released Notice 2020-76 on October 2, 2020, announcing a delay in the deadline for distribution of Forms 1095-B and Forms 1095-C to participants by employers, health insurers and other...more
Similar to last year, in Notice 2020-76, the Internal Revenue Service (the “IRS”) has extended the deadlines for delivery (but not filing) of the 2020 Forms 1094 and 1095 required by the Affordable Care Act (the “ACA”)....more
In response to the repeal of the individual health coverage mandate, New Jersey passed the New Jersey Health Insurance Market Preservation Act (the "Act") which generally requires individuals who reside in New Jersey to...more
The IRS Office of Chief Counsel recently issued a memo which, in a surprise to many, concluded that the filing of the Affordable Care Act (“ACA”) Forms 1094-C and 1095-C (“C Forms”) does not start the statute of limitations...more
The Internal Revenue Service (IRS), in a recently released memorandum from the Office of Chief Counsel (Chief Counsel Memorandum), has taken the position that the Employer Shared Responsibility Payment (ESRP) imposed by...more
As we reminded employers back in December, the IRS has extended the Affordable Care Act (“ACA”) deadline for health plan sponsors to furnish individuals IRS Forms 1095-B and 1095-C until March 2, 2020....more
As it has done in past years, the IRS has extended the Affordable Care Act (“ACA”) deadline for health plan sponsors to furnish individuals IRS Forms 1095-B and 1095-C by 30 days (IRS Notice 2019-63). ...more
You’ve been at this Affordable Care Act reporting for years and are cruising on autopilot, right? Regardless of your confidence level, all employers need to note the extended due date for furnishing Form 1095-C to individuals...more
Last week, the IRS issued it updated Form 1094-C and 1095-C instructions for 2019. Employers that employ New Jersey residents, however, may have more reading to do. New Jersey responded to the federal repeal of the Affordable...more