The Internal Revenue Service (“IRS”) has released the final 2024 forms for reporting under Internal Revenue Code (“IRC”) Sections 6055 and 6056 (Forms 1094-B, 1095-B, 1094-C, and 1095-C), along with related final instructions. No major changes were made to the final forms or instructions for 2024 reporting.
Employer Action Items
- Employers should become familiar with these forms and instructions for the 2024 calendar year reporting and, if necessary, begin to explore options for filing ACA reporting returns electronically (e.g., work with a third-party vendor to complete the electronic filing).
- As a reminder, not only are applicable large employers required to file on the coverage offered to their full-time employees, but small employers with level or self-funded health plans also have a filing requirement under IRC Section 6055 to report coverage information.
Summary
Individual statements for 2024 must be furnished to employees by March 3, 2025, and electronic IRS returns for 2024 must be filed by March 31, 2025. For the limited few that may still be allowed to file on paper, that deadline is February 28, 2025.
As a reminder, several states, including California, Massachusetts, New Jersey, Rhode Island, as well as the District of Columbia, have their own reporting requirements to evidence an employee’s compliance with the individual mandate. Deadlines may differ from the federal law requirements noted in the previous paragraph.
Additional Resources
- Final Form 1094-B (https://www.irs.gov/pub/irs-pdf/f1094b.pdf)
- Final Form 1095-B (https://www.irs.gov/pub/irs-pdf/f1095b.pdf)
- Final Form 1094-C (https://www.irs.gov/pub/irs-pdf/f1094c.pdf)
- Final Form 1095-C (https://www.irs.gov/pub/irs-pdf/f1095c.pdf).
- 2024 Instructions for Forms 1094-C and 1095-C (https://www.irs.gov/pub/irs-pdf/i109495c.pdf).
- 2024 Instructions for Forms 1094-B and 1095-B (https://www.irs.gov/pub/irs-pdf/i109495b.pdf).
For more information
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