Affordable Care Act Update 2023
Filing Deadlines
The filing deadline for employers to provide employees with a copy
of their 2025 1095-C reporting form, as required by the Affordable
Care Act, is March, 2 2026. The deadline for electronic submissions
to the IRS is March 31, 2026 (submit filing via AATRIX by March
27th to guarantee compliance).
Website notice instead of distributing ACA forms
For 2025 forms (due in 2026), employers and other coverage
providers are no longer required to automatically furnish forms to
employees. Instead, they can post a “clear, conspicuous, and
accessible” notice on their website stating that a Form 1095 will be
provided upon request. This change was made by the Paperwork
Burden Reduction Act. However, entities must still comply with
state-level distribution mandates. The notice must (1) be placed in
a location on the employer’s website that is reasonably accessible to
all impacted individuals, (2) state that individuals can receive a copy
of the Form 1095-C upon request and explain the process for
making such request, and (3) include contact information to make
the request and follow-up regarding any questions. To use the
website notice option, the notice must be posted by March 2, 2026,
and must remain on the website through October 15, 2026. The
change to allow website notice has no effect of IRS filing
requirements.
Lowest Cost for Offer of Coverage Code ‘1A’ Increases for
2025
The lowest monthly amount the employee could have paid under
the plan for self-coverage only (the cost for covering spouse or
dependents is not included) and use Offer of Coverage code ‘1A’
was $101.93 for the 2024 tax year. In 2025 this amount has
increased slightly to $113.20 (based on 9.02% of $15,060, the
2024 poverty level divided by 12). In 2025, if the lowest monthly
amount the employee could have paid is less than $113.20 per
month for minimum value coverage as defined by the law, Offer of
Coverage Code ‘1A’ can be used. If the lowest monthly amount is
more than $113.20, Code ‘1A’ cannot be used and the employer
should fill in the amount on the form (line 15) and use one of the
‘Safe Harbor Codes’, if applicable, to show that the employer is in
compliance.
For 2026 plans using the Poverty Level Safe Harbor to determine
affordability, the employee’s premium payment will not be able to
exceed $129.89 per month (calculated as 9.96% of $15,650 the
2025 poverty level, divided by 12).
State Level Reporting
In addition to the federal mandate that requires electronic
submission of forms to the IRS, employers also have an obligation
to submit returns at the state level in these states: California,
New Jersey, Rhode Island, and the District of
Columbia. Massachusetts also has its own special ACA
guidance. Connecticut, Hawaii, Maryland,
Minnesota, and Washington have proposed bills to follow suit in
upcoming years as well.
New Jersey’s individual health coverage mandate requires thirdparty reporting to verify health coverage information supplied by
individual payers of New Jersey’s Income Tax. The requirement
includes both in-state and out-of-state employers who provide
health coverage to New Jersey residents. New Jersey‘s electronic
filing is due March 31 following the end of the calendar
year. Typically only self-insured plans need to be reported as most
fully insured plans are reported by the insurance carrier. Mailing in
paper forms is NOT an option for New Jersey ACA filing.
When submitting forms electronically via Aatrix please make sure
that you have marked the appropriate fields to indicate that Aatrix
should also submit the required state ACA forms for employees who
reside in those states.
Form 1095-C
IRS Forms 1094-C and 1095-C have not changed for 2025
reporting.