
Final Forms & Instructions for IRS’s 2024 ACA Reporting Available
The IRS has released final forms and instructions for Affordable Care Act (ACA) information reporting for 2024, including Forms 1094-C, 1095-C, 1094-B and 1095-B. As a reminder, employers subject to the ACA’s shared responsibility penalties, i.e., applicable large employers or ALEs (employers with 50+ full-time or full-time equivalent employees), generally report health plan offer and coverage information to the IRS via Forms 1094-C and 1095-C. (Forms 1094-B and 1095-B are only used by non-ALE employers [small employers] with a self-funded plan.) Employers can access the updated forms and instructions here.
The forms are essentially unchanged from 2023. The C form instructions reflect that the affordability safe harbor and qualifying offer method are applied using the percentage as adjusted for 2024, which is 8.39%. For calendar year 2024, Forms 1094-C and 1095 C are required to be filed with the IRS by February 28, 2025 (if filing on paper), or March 31, 2025, if filing electronically. (Filers may seek an extension of these deadlines by application to the IRS using Form 8809.) The deadline for furnishing statements to employees is March 3, 2025. Filers with ten or more returns in the aggregate must file their Forms 1094-C and 1095-C electronically. Filers must consider in the aggregate almost all information return types (including these forms, Forms W-2, and 1099) to determine if the ten-return threshold is met. Publications 5165 (guide for electronically filing ACA information returns for software developers and transmitters), 5258 (ACA AIR submission composition and reference guide), and 5308 (guide for automated enrollment for ACA providers), have also been revised.
With the issuance of the final forms and instructions—and availability of updated Publications with technical details related to electronic filing—filers should have the tools they need to prepare for filing the 2024 forms.
Please visit www.moreton.com/news-events/ for more information and to view other client alerts. This Client Alert was written by Carolyn Cox, who provides our clients with compliance services. For additional questions, please contact Carolyn at 801-715-7110 or [email protected].
© 2024 by Moreton & Company. This Client Alert is intended to alert recipients to recent legal developments. It does not constitute the rendering of legal advice or recommendations and is provided for your general information only. If you need legal advice upon which you can rely, you must seek an opinion from your attorney.