Deadlines for Affordable Care Act (ACA) reporting for the 2024 tax year are swiftly approaching. The IRS has released final forms and instructions for 1094-C and
1095-C. As a reminder, Forms 1094-C and 1095-C are filed by applicable large employers (ALEs) to provide information that the IRS needs to administer employer shared responsibility penalties and eligibility for premium tax credits, as required under Code § 6056. The forms are essentially unchanged from 2023; however, the C form instructions reflect that the affordability safe harbor and qualifying offer method are applied using the percentage as adjusted for 2024, which is 8.39%. To view the full instructions and forms provided by the IRS, click the links below:
Instructions for Forms 1094-C and 1095-C
In preparation for form filings, here are a few things you should note:
Who Is Required to Report?
1094-C and 1095-C: Under the Affordable Care Act, all “Applicable Large Employers” (generally those with 50 or more full-time employees, including full-time equivalents or FTEs) will use Forms 1094-C and 1095-C to report information to the IRS and to their employees about their compliance with the employer-shared responsibility provisions (“pay or play”) and the health care coverage they have offered. Employers subject to both reporting provisions (generally self-insured employers with 50 or more full-time employees, including FTEs) will satisfy their reporting obligations using these two "C Forms."
What Are the Deadlines?
The deadlines are as follows:
Deadline for Furnishing Statements to Individuals
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The deadline for furnishing Forms 1095-C to individuals is March 3, 2025.
Filing Returns With the IRS
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All Applicable Large Employers must submit their Form 1094-C to the IRS electronically by March 31, 2025.
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Employers filing electronically should refer to the IRS for more information on the AIR Program, which requires at least 30 days for testing for first-time users.
Filers may extend these deadlines by application to the IRS using Form 8809.
How Will MedCost Assist Clients?
MedCost is generating reports for our clients that will be available as early as the week of December 16, 2024. Reports will be posted to the secure Employers portal of our website. Details on how to use the reports and the report contents will be discussed in a future communication.
Questions?
As always, MedCost is here to assist you with ACA reporting requirements. If you have any questions or need additional information, please contact your Account Manager or MedCost Compliance at [email protected].