By: The Affordable Care Act (ACA) mandates specific reporting requirements for applicable large employers (ALEs), generally those with 50 or more full-time equivalent (FTE) employees, as well as self-insured employers of any size. For plan year 2024, the reporting process for employer-provided health coverage is largely unchanged, but deadlines remain crucial. Here is a summary of the 2024 ACA reporting requirements and deadlines:
Who is Required to File
Under Section 6056 of the Internal Revenue Code, an Applicable Large Employer (ALE) must report information on Form 1095-C that discloses if an employer is subject to an assessment of a Shared Responsibility Payment. Generally, an ALE is an employer with fifty (50) or more full-time equivalent (FTE) employees during the previous calendar year. This may include employers that are part of an aggregated ALE group due to significant common ownership or control stemming from related employer entities. If you are unsure whether your organization is an ALE, contact us to discuss.
- The ACA requires Applicable Large Employers (ALEs) to report whether they offered minimum essential coverage (MEC) that was affordable and provided minimum value to full-time employees.
- Employers of any size with self-insured plans (including level funded) also report months of coverage for all individuals.
- ACA reporting for fully insured ALEs is handled via IRS Forms 1094-C and 1095-C. Self-insured employers, regardless of size, must complete and submit Forms 1095-B and 1094-B for reporting minimum essential coverage (MEC).
2024 ACA Reporting Deadlines
The IRS has updated reporting deadlines as follows:
- Employee Form Distribution: Forms 1095-B and 1095-C must be distributed to employees by January 31, 2025.
- IRS Filing: Employers filing 10 or more returns (this number includes 1095 forms, W-2 and 1099 forms) must file electronically by March 31, 2025.
Penalties for Reporting Non-Compliance
Employers that fail to file electronically when required, miss reporting deadlines, or submit inaccurate information may incur penalties. These can reach up to $330 per form, with a maximum annual penalty of over $3.9 million for ALEs. Meeting the ACA’s reporting requirements is critical for ALEs and self-insured employers.
If Suttle & Stalnaker prepared your plan year 2023 1095-C forms, we will be sending you the 2024 data template in the coming week.
Suttle & Stalnaker, PLLC is ready to help you. Our HR Consulting team has the knowledge and expertise to help you, and your business navigate the Affordable Care Act (ACA) reporting complexities. Please contact Drema Foster, PAFM at 304.343.4126 or dfoster@suttlecpas.com our office if you need assistance with reporting or if you have other ACA related questions or concerns.