The IRS recently released the final forms and instructions for reporting under the Affordable Care Act (ACA) for 2023. These forms are crucial for brokers and employers, as they provide essential information to ensure adherence to the latest regulatory requirements.
What are these forms for?
1094-B and 1095-B are submitted by those providing minimum essential coverage (MEC), such as health insurers and self-insured health plan sponsors, to report coverage details as required under Code § 6055. 1094-C and 1095-C are filed by applicable large employers (ALEs) to provide information necessary for the IRS to administer employer-shared responsibility penalties and eligibility for premium tax credits, as mandated by Code § 6056.
What's new in 2023?
The forms themselves remain pretty much unchanged from 2022. However, there's a significant modification when it comes to filing. In the past, filers submitting fewer than 250 returns could file their reporting forms by paper. Starting in 2024, for the 2023 filings, filers with ten or more returns in total must file Forms 1094-B, 1095-B, 1094-C, and 1095-C electronically. This change encompasses nearly all information return types (including Forms W-2 and 1099). The penalty for failing to file electronically is also increasing to $310 per return (previously $290), with a maximum of $3,783,000 (previously $3,532,500) for filers with more than ten returns.
Important Deadlines
February 28, 2024: Deadline to file Forms 1094-B and 1094-C for the calendar year 2023 by mail.
March 1, 2024: Deadline to furnish 2023 statements to individuals.
March 31, 2024: Deadline to file Forms 1094-B and 1094-C for the calendar year 2023, if filing electronically
Note: Extension requests are available for filing deadlines using Form 8809.
These recent updates in ACA reporting for 2023 highlight the shift towards electronic filing and the elimination of paper filing for most employers. It's important for employers who are used to filing via mail to transition to electronic filing while being mindful of aggregation rules and effective dates. Staying informed and compliant with these changes is crucial to avoid hefty penalties and ensure a smooth reporting process. And as always, we’re here to help! Did you know our ACA experts have eliminated over $100 million in IRS penalties for our clients? Medcom offers ACA solutions so you don’t have to deal with the complex regulations of the Affordable Care Act. Our team helps you every step of the way, from data collection to filing with the IRS. If you have any questions, don’t hesitate to contact our dedicated ACA Sales Specialist, Tom Neal.
Final instructions for 1094-B and 1095-B are available on the IRS website: https://www.irs.gov/pub/irs-pdf/i109495b.pdf.
Final instructions for 1094-C and 1095-C are available on the IRS website: https://www.irs.gov/pub/irs-pdf/i109495c.pdf.
Read more: IRS Announces 2024 ACA Affordability Percentage.
