Recent Legislation Simplifies ACA Tax Reporting

Two recent pieces of federal legislation, which were signed into law in late December 2024, simplify Affordable Care Act (ACA) tax reporting beginning with the 2024 tax year.

Under the Paperwork Burden Reduction Act, plan sponsors and employers are no longer required to provide 1095-B and 1095-C forms directly to full-time employees and covered individuals, though they may continue to do so. Instead, they can notify affected individuals of their right to request the forms (e.g., posting the notice on their website). If forms are requested, they must be provided within 30 days of the request or by January 31, whichever is later.

The Employer Reporting Improvement Act includes the following regulations:

• Permits electronic delivery of 1095 forms instead of using first-class mail or in-person delivery, as previously required, if an individual has consented to electronic delivery for these statements previously and has not revoked his or her consent.
• Extends the time for employers to respond to a 4980H(d) penalty letter to 90 days from the receipt of the initial letter.
• Clarifies that the statute of limitations for penalty assessment is six years from the filing due date or the date the filing was made, whichever is later.
• Codifies previous Internal Revenue Service guidance that allows the use of a covered individual’s full name and date of birth for coverage reporting if the employer is unable to obtain the individual’s tax identification number, such as a Social Security number.

If 1095 forms are delivered by first-class mail, in-person or electronically for the 2024 tax year, they must be provided to covered individuals no later than March 3, 2025.*

*March 1 falls on a Saturday in 2025, pushing the deadline to the next business day, March 3, 2025.

The ACA tax filing dates remain:

• February 28, 2025, to file forms with the IRS by paper.
• March 31, 2025, to file forms with the IRS electronically.

Final NRECA Data Reports
NRECA will release the final ACA data reports for the NRECA Medical Plan and health reimbursement arrangements administered by Cooperative Benefit Administrators to cooperatives’ primary benefits administrators through the Message Center by the end of the week.

For general questions on ACA tax reporting, speak with Juliana Overstreet at 703.907.6492 or juliana.overstreet@nreca.coop. For questions on the NRECA data report for medical plans, contact ifsdatareporting@nreca.coop. For questions on the health reimbursement arrangement data report, contact Dianne Payne at 703.907.5702 or dianne.payne@nreca.coop. You also can contact the Member Contact Center at 866.673.2299 or contactcenter@nreca.coop.

This article is provided for informational purposes only. NRECA isn’t authorized to provide tax or legal advice to co-ops about this topic. Co-ops should seek confirmation of this information from their tax or legal advisors.