The IRS recently released Notice 2025-15, clarifying how employers may comply with the new requirements for furnishing Forms 1095-B and 1095-C, Employer-Provided Health Insurance Offer and Coverage, by using the alternative method as allowed (e.g. posting the notice to the employerโs website) in the Paperwork Burden Reduction Act. Hereโs what you need to know. ย
Remember: ย
The headline: Employers are no longer automatically required to send Forms 1095-B and 1095-C to all full-time employees and covered individuals. Instead, employers can post a notice on their company website explaining how employees can request the appropriate form. ย
But donโt skip the detailsโthere are conditions to stay compliant.ย ย
Switching from mailing forms to posting a notice online? Hereโs what the IRS requires:ย ย
The notice should be in a location on its website that is reasonably accessible to all responsible individuals, with information on how individuals may request a copy of their respective form upon request. The notice should be accessible to all current employees, COBRA participants, and retirees. No hidden links! ย
Provide your email, physical address, and phone number for employees to request their respective form or ask questions. ย
Use simple language and a readable formatโno tiny fonts or jargon.ย ย
The posted notice must be available by the due date for furnishing the statement, including the automatic 30-day extension (e.g., for 2024 statements, the notice must be posted by March 3, 2025).ย
Keep It Onlineย ย
The notice needs to stay up through October 15, 2025, for 2024 forms.ย ย
Switching to website notices saves time and money but comes with some reminders:ย ย
Federal changes donโt override state laws. Reporting guidelines for California and the District of Columbia may suggest that complying with the IRS requirement to furnish the respective form would satisfy the respective state’s requirements. However, the New Jersey and Rhode Island guidance refers to providing a written statement and does not specify that complying with the federal furnishing satisfies the state furnishing requirement. ย Check with your employee benefits attorney to ensure that if you operate in a state that requires furnishing the respective form that you do it compliantly.ย
Keep your messaging simple to avoid confusion and questions from employees. The notice must be in plain, non-technical terms and visually clear.ย
Pro Tip: If you have an administrator assisting with these forms, ensure that you coordinate distribution well in advance of any deadlines.ย
The Paperwork Burden Reduction Act (H.R. 3797) amended IRC Sections 6055(c) and 6056(c) to allow an alternative method of furnishing Forms 1095-B and 1095-C (see โNew Requirements for ACA Forms 1095-B and 1095-Cโ). Under this Act, reporting entities are not required to send forms to individuals so long as the entity posts a notice prominently on their website that individuals may receive their respective form upon request. If requested by the participant, their form must be furnished by the earlier of (1) January 31 of the year following the calendar year for which the return was required to be made or (2) 30 days after the request. The posted notice must be available by the due date for furnishing the statement, which for 2024 is March 3, 2025.ย
This change is a great opportunity to streamline ACA reporting while staying compliant. Plan ahead, communicate clearly, and youโll be ready.ย ย
Have questions? Donโt stressโweโre here to help. Stay compliant, keep your employees informed, and let this update work to your advantage!ย
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