In Notice 2025-15, the IRS provides guidance on the alternative method for furnishing forms 1095-B and 1095-C reporting health coverage an employee had or was offered throughout the year. Instead of requiring that the forms be furnished automatically to all full-time employees of applicable large employers (ALEs) and other entitled recipients, the alternative method allows the forms to be provided only upon request.
The guidance may be most helpful for future reporting years, as the deadline for posting the notice required in order to use the alternative method for 2024 statements is March 3, 2025.
The Paperwork Burden Reduction Act (PBRA), signed by President Biden in December 2024, eased the reporting process under the Affordable Care Act (ACA) by allowing reporting entities to furnish Forms 1095-B and 1095-C to individuals only upon request rather than automatically each year.[1]
Under Internal Revenue Code (IRC) section 6055, entities providing minimum essential coverage (MEC) must furnish a statement (generally Form 1095-B, but ALEs with self-insured health coverage may use Form 1095-C) to covered individuals regarding the health coverage they had during the calendar year. Under IRC section 6056, ALEs must provide Form 1095-C to full-time employees regarding the coverage they were offered during the calendar year. These statements must be furnished on or before January 31 of the year following the calendar year to which they relate. IRS regulations issued in 2022 permanently extended this deadline by 30 days (i.e., March 3, 2025, for 2024 statements).
Reporting entities that choose to use the alternative method must notify — in a clear, conspicuous and accessible manner — all full-time employees and covered individuals that they may request a copy of the statement. The notice must:
Once a request is received, the reporting entity has until January 31 of the year after the calendar year to which the form relates or 30 days after the request is received, whichever is later, to provide the form. The forms may be delivered electronically to any employee who consents to electronic distribution.
Note, in states that have their own minimum essential coverage and related reporting requirements, employers must continue to provide the notices automatically unless those states have adopted the alternative method.
As of the date of this writing, the instructions for Form 1095-C have not been updated to reflect this new guidance, but an ALE choosing to use the alternative method for Form 1095-C can follow the Form 1095-B instructions on page 6 for non-full-time employees.
