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New for 2024 - Electronic Filing Requirements

Monday, January 29, 2024

Final Rule Significantly Expands IRS Electronic Filing Requirement

The following is intended for informational purposes only and is not legal or tax advice. If you have questions, please call us and/or your legal or tax professional. All carrier information contained herein is subject to change.

The Affordable Care Act (ACA) created reporting requirements under Internal Revenue Code Sections 6055 and 6056. Under these rules, certain employers must provide information to the IRS about the health plan coverage they offer (or do not offer) to their employees and individuals enrolled in level-funded or self-funded coverage. Any reporting entity required to file at least 250 individual statements under Sections 6055 or 6056 must file electronically.

Beginning in 2024, employers that file at least 10 returns during the calendar year must file electronically. Due to the lowered threshold, only the smallest employers can file using paper returns. Reporting entities must aggregate most information on returns, such as Forms W-2 and 1099, to determine if they meet the 10-return threshold for mandatory electronic filing.

The forms must be provided to covered individuals by March 1, 2024. The due date for filing the forms electronically is April 1, 2024.

Please see attached for more information on how your carrier or TPA will provide the information to assist you in completing the forms and e-filing for the 2023 reporting year.


Employer Reporting Requirements:

Level-Funded/Self-Funded Employers that are Not Applicable Large Employers (ALEs)

  • Complete the 1095-B and provide it to covered individuals by 3/01/2024.
  • Complete the 1094-B and E-file the 1094/1095-Bs to the IRS by 4/01/2024.

Level-Funded/Self-Funded Applicable Large Employers (ALEs)

  • Complete Part 111 of the 1095-C for all covered individuals in addition to Part 1 and 11 on the 1095-C and provide it to employees by 3/01/2024.
  • Complete the 1094-C and E-file the 1094/1095-Cs to the IRS by 4/01/2024.

  Fully Insured Applicable Large Employers (ALEs)

  • Complete the 1095-C and provide it to employees by 3/1/2024.
  • Complete the 1094-C and E-file the 1094/1095-Cs with the IRS by 4/01/2024.