Understanding the New ACA Reporting Relief for Employers
March 7, 2025
At the close of last year, we highlighted the introduction of new legislation that offers employers some relief in Affordable Care Act (ACA) reporting duties. The Paperwork Burden Reduction Act now allows applicable large employers (ALEs) to forego automatically distributing Form 1095-C to employees. Instead, ALEs are simply required to inform employees they can request this form through a 'clear and conspicuous notice.' Recently, the IRS released Notice 2025-15, providing clarity on what constitutes such a notice.
Key Elements of Notice 2025-15
The Notice outlines specific conditions ALEs must meet if they wish to provide a notice instead of the automatic distribution of Form 1095-C:
- The notice must be accessible to any individual for whom a 1095-C is filed, including current and former employees like COBRA enrollees and retirees.
- Contact information—an email address, physical address, and phone number—must be provided for individuals to request their Form 1095-C or raise inquiries.
- The notice should use plain, non-technical language, and font size sufficiently large to draw attention to its importance regarding Form 1095-C.
- It must be posted on the website by the Form 1095-C due date, which includes the 30-day extension. For the 2024 forms, that date is March 3, 2025.
- The notice should remain visible on the website until October 15 of the following year, making the deadline for 2024 forms October 15, 2025.
Example of a Compliant Notice
To ensure compliance, ALEs can include a 'Tax Information' link on their main web page that leads users to a separate page. This secondary page should prominently display 'IMPORTANT HEALTH COVERAGE TAX DOCUMENTS,' accompanied by instructions to request Form 1095-C and providing relevant contact information including an email, mailing address, and phone number.
Additional Requirements and Recommendations
The Notice also states that ALEs must supply a requested Form 1095-C within 30 days, and it may be provided electronically with the employee's consent.
Even under this relief, ALEs must still file Forms 1094-C and 1095-C with the IRS by March 31, 2025, if filing electronically, or by February 28, 2025, if using paper. Employers looking to reduce costs associated with mailing Form 1095-C should consider posting a compliant notice as outlined. It’s important to note that this relief applies only at the federal level; employers should verify state-level requirements, especially in states like California with separate reporting.
For many business owners, bringing independent contractors on board is a practical choice that brings flexibility and specialized skills. However, it's crucial to understand the liability risks associated with using such workers. A common misconception is that a General Liability (GL) policy offers blanket coverage, but the truth is far more complex. It's essential to recognize the potential risks if contractors don't have their own insurance coverage.
In today’s uncertain world, financial planning is not just a smart move—it’s essential for protecting your loved ones. One of the key components of a strong financial plan is choosing the right insurance policy. For many, this decision boils down to a choice between life insurance and Accidental Death and Dismemberment (AD&D) insurance, two options that can be confusing at first glance. In this blog, we’ll break down the key differences to help you make an informed choice.
Summer travel season is just around the corner, with enticing destinations calling us away from our daily routines into the embrace of exploration and relaxation. Whether you're gearing up for a sun-soaked beach escape, a thrilling mountain adventure, or a culturally rich city break, one aspect of your travel checklist deserves more attention than it often gets: travel insurance. This essential safety net ensures that even with the most passionate planning, your dream vacation can be protected against unexpected curves the journey may throw your way.
Have you ever meant to purchase life insurance but found yourself putting it off time and again? You're not alone. It's a common scenario, full of good intentions yet stalled by various hurdles along the way. Many of us have experienced this delay, and it's important to understand that the hesitation often stems from something deeper than mere procrastination or neglect.
Our daily existence is becoming digitally integrated at an unprecedented pace, making cybersecurity a paramount concern. From online shopping and social networking to managing smart homes, our personal and financial information is more exposed than ever. High-profile incidents, such as the Grubhub data breach and PlayStation Network hacks, highlight the vulnerability of our digital lives. Despite this, many people believe their home insurance covers cyber risks, which is often not the case. This is where cyber insurance becomes crucial.
Navigating the world of liability insurance can be daunting, especially when working with independent contractors. Many business owners mistakenly assume that their General Liability (GL) policy covers all potential risks associated with their independent contractors. However, the reality is more nuanced, and misunderstanding these risks can lead to significant exposure if contractors don't have their coverage.
Financial planning plays a crucial role in safeguarding the well-being of your loved ones. It's an essential step to ensure that, in unforeseen circumstances, your family remains secure. As part of this planning, understanding the nuances of various insurance options, such as life insurance and accidental death and dismemberment (AD&D) insurance, becomes imperative. Many people find these terms confusing, yet making an informed choice between them can significantly impact your financial safety net.
If you've ever thought about getting life insurance but never quite got around to it, you're not alone. Many people find themselves with the best intentions to secure their financial future, only to let the task linger just out of reach. It’s important to know that this hesitation isn't solely about procrastination or neglect—there's a deeper, shared experience at play here.
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Understanding Employee ReworkEmployers often face questions about whether they must compensate employees who voluntarily put in extra hours to fix their own mistakes. This issue frequently arises when an employee chooses to correct errors outside of regular working hours without explicit instructions from management.Legal Obligations Under Federal LawAccording to the Fair Labor Standards Act, if an employer permits or requires employees to work, the time is generally considered hours worked and must be compensated. Even if the work is not directly requested, if the employer benefits from it and is aware it is being done, it counts as hours worked. This is typically referred to as working off the clock.The Importance of Management OversightIf employees are correcting their own mistakes—referred to as "rework"—the time they spend on these tasks is considered hours worked and should be compensated. Employers are responsible for maintaining control, ensuring that unnecessary work is not being performed, and recognizing that time spent on rework should be compensated.Addressing Performance IssuesIn at-will employment settings, continuous errors that result in rework can be treated as a performance issue. Employers have the right to address these issues through disciplinary measures, which can include termination if necessary. It's crucial that employers apply performance policies consistently to prevent discrimination claims or perceptions of unfair treatment.
