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IRS Publishes New Electronic Filing Rules for ACA Forms

Since 2013, employers have been compelled to comply with the Affordable Care Act’s requirement to file Forms 1094-C and 1095-C to the IRS annually. In these last ten years, Employers with under 250 forms could do so via paper filing; those with over 250 had to file electronically. The IRS first proposed a rule to decrease the threshold for paper filing back in 2021. Well, they’ve finally done it, and a lot more abruptly than they first announced.

On February 23, 2023, the IRS published the final rule for Electronic Filing. Under this rule, the threshold for filing electronically is now reduced to ten forms or more commencing in the 2024 calendar year. Now, employers with less than ten forms can file by mail, and those exceeding ten may utilize electronic filing procedures. This is a significant difference from the previous minimum of 250.

The IRS states:

Returns required electronically. (1) If the use of Form 1042-S, Form 1094 series, Form 1095-B, Form 1095-C, Form 1097-BTC, Form 1098, Form 1098-C, Form 1098-E, Form 1098-Q, Form 1098-T, Form 1099 series, Form 3921, Form 3922, Form 5498 series, Form 8027, or Form W-2G is required by the applicable regulations or revenue procedures for the purpose of making an information return, the information required by the form must be submitted electronically, except as otherwise provided in paragraph (c) of this section. Returns filed electronically must be made in accordance with applicable revenue procedures, publications, forms, or instructions.”

Applicable Large Employers (ALE) this applies to you! All ALEs must be aware of this new electronic filing requirement and begin planning for the 2024 filing year to ensure they can file electronically. We’re seeing this reduction by the IRS as an attempt to phase out paper filing.

As the IRS transitions to more electronic submissions, the process will be much more efficient both on their end and the employer’s. No more waiting around to see if your filings have been submitted, everything is time-stamped, which will help in an audit, plus you get more time to file (March 31 vs. the paper filing deadline of February 28).

As always, make sure you are submitting information accurately and on time! Medcom is here to fill any of the gaps. Please contact us if you have any questions about ACA filing or to see how we can help you complete your ACA compliance requirements correctly and on time every time!