Early in 2025, the IRS issued Notice 2025-15, providing guidance on an optional alternative method employers may use to satisfy ACA reporting requirements under Internal Revenue Code Sections 6055 and 6056 to furnish health coverage statements to individuals, including full-time employees of applicable large employers (ALEs).
Background
Under the ACA, certain entities must annually report health coverage information.
- Section 6055 applies to providers of minimum essential coverage (MEC), such as health insurers and self-insured employers. These entities file Form 1094-B and 1095-B with the IRS and furnish Form 1095-B to covered individuals.
- Section 6056 applies to ALEs (employers with more than 50 full-time and full-time equivalent employees). ALEs file Form 1094-C and 1095-C with the IRS and furnish Form 1095-C to their full-time employees about the coverage offered.
Historically, employers were required to furnish paper statements to all employees. Notice 2025-15 clarifies when they may instead use a streamlined method based on online posting and requests.
The Alternative Manner of Furnishing Statements
The Paperwork Burden Reduction Act amended IRC Sections 6055(c) and 6056(c) to allow a reporting entity to comply if it:
- Provides clear and conspicuous notice, in a location on its website that is reasonably accessible to all responsible individuals, that the individual may receive their statement upon request.
- Furnishes the statement upon request in a timely manner.
The alternative method is available to ALEs, self-insured employers and other MEC providers, and health insurers. This method does not alter IRS filing requirements; it only affects how statements are furnished to individuals.
The notice must be posted by the due date for furnishing statements (including the automatic 30-day extension) and retained in the same location at least through October 15 following the applicable plan year. It must include the email address, telephone number, and physical mailing address for statement requests.
If an individual requests a copy of their 1095 form, the employer must furnish it within 30 days of the request or by January 31 of the year following the calendar year to which the form relates, whichever is later. Employers may furnish statements electronically if permitted under applicable electronic consent rules.
For the 2025 calendar year reporting, Forms 1095 must be furnished to employees by March 2, 2026, whether in paper or using the alternative notice method.
Employer Action Items
- Evaluate the cost and administrative savings from reducing mass distribution of 1095 forms.
- Consider employee population and communication channels to ensure effective notice access.
- Ensure the notice is prominently displayed on your public website or an employee portal.
- Maintain an archive of annual notices and retention through October 15.
- Assign responsibility for processing requests within the 30-day window.
- Create clear internal tracking and documentation for requests and responses.
- Confirm that electronic delivery meets regulatory requirements (including employee consent where required).
- Remember that some states or localities may have separate health coverage reporting requirements that are unaffected by federal changes.
- Align ACA reporting processes with payroll and HR systems to ensure timely filing and furnishing.
