Forms 1094-C, 1095-C, 1094-B, and 1095-B are among the final instructions and forms that the IRS has made available for calendar year 2024 ACA reporting. As a reminder, since good faith relief from penalties is no longer available, it is crucial to make sure the forms are accurate, timely, and submitted to the IRS.
There are no significant changes to the 2024 forms
Forms 1094-C/1095-C
Applicable large employers (ALEs) must provide Form 1095 to full time employees and Form 1094-C and 1095-Cs will be filed with the IRS. Covered employees or other primary insured individuals in the self-funded health plan must also receive Forms 1095-C from ALEs that offer a self-insured group health plan, including level-funded arrangements and individual coverage health reimbursement arrangements (“ICHRAs”).
On March 3, 2025, Form 1095-C for the 2024 calendar year must be provided by full time employees and other individuals. While Form 1094-C and all Forms 1095-C must be filed by March 31, 2025,with the IRS electronically.
Forms 1094-B/1095-B
Employers who provide self-funded group health plan coverage such as level-funded plans and ICHRAs but are not ALEs are required to provide and submit documentation pertaining to minimum essential coverage. In particular, the employer discloses the coverage they had during the calendar year to the IRS and all covered individuals as the self-funded plan’s provider. Forms 1094-B and 1095-B are used by employers to comply with this obligation.
On March 3, 2025, Form 1095-B for the 2024 calendar year must be provided by covered individuals. While Form 1094-B and all Forms 1095-B must be filed by March 31, 2025, with the IRS electronically.
Penalty
According to the instructions, employers who sponsor self-funded group health plans, including ALEs, may be subject to the general reporting penalty provisions for failing to file accurate information returns and provide accurate payee statements if they do not comply with the information reporting requirements. Relief in good faith is no longer accessible.
For 2024, the following penalties may apply:
- Failure to file a correct return is $330/statement (total calendar year penalty not to exceed $3,987,000).
- Failure to furnish a correct statement is $330/statement (total calendar year penalty not to exceed $3,987,000).
An employer that fails to both file and furnish a correct statement is subject to a combined penalty of $660/statement with a maximum penalty of $7,974,000.
Have Questions? and want to read more about the changes? Check Final 2024 ACA Reporting Instructions and Forms Issued for more details
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