ACA Timing Guide for HR Professionals

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In the dynamic landscape of employee benefits administration, Affordable Care Act (ACA) compliance stands as an important responsibility for HR professionals. Understanding the reporting timeframes is critical to ensure accurate and timely form distribution and IRS submissions.

• Furnishing Form 1095-C to Employees: Employers subject to the ACA’s employer mandate, also known as applicable large employers (ALEs), are obligated to provide Form 1095-C to full-time employees by March 1, 2024, for the 2023 tax year. ALEs are entities with 50 or more full-time or full-time equivalent employees.

Form 1095-B to Covered Individuals:

• Entities that provide minimum essential health coverage, including insurers and self-funded employers not subject to the employer mandate, are required to furnish Form 1095-B to covered individuals. This includes employees and other individuals covered by the health plan.

Electronic Filing with the IRS:

• ALEs filing electronically with the IRS must meet the April 1 2024 deadline (the regular deadline of March 31 falls on a weekend). This electronic submission is part of the comprehensive reporting process to provide required information to the IRS.

Paper Filing with the IRS:

• Starting in 2024, most employers are required to file their 1095 forms electronically. Employers that collectively file 10 or more information returns of any sort (W-2, 1099, 1095) must transmit data to the IRS electronically. All informational forms are aggregated in determining the 10-return threshold.

Corrections and Amendments:

• In the event of errors or the need for corrections, HR teams should be aware of the procedures and timeframes for making amendments. Timely corrections are crucial to maintain compliance and avoid potential penalties.

Consideration for COBRA Continuants:

• When reviewing ACA reporting, HR teams must not overlook individuals on COBRA continuation coverage. Special attention should be given to the accurate reporting of offers of coverage for these individuals.

Adhering to these reporting timeframes is not only a legal obligation but also a strategic move in maintaining transparency and accuracy in benefits administration. HR professionals should initiate a comprehensive review of their ACA reporting processes well in advance of the deadlines. This includes ensuring the accuracy of data, coordinating with relevant departments, and utilizing efficient reporting tools to streamline the process. For Information about BAS’ ACA Data Collection and Reporting Services, contact your account manager or solutions@basusa.com.