Simplify ACA Reporting with Our Affordable and Accurate Solution

The IRS recently issued Notice 2025-15 which provides employers with specific guidance on the alternative method for furnishing Form 1095-C to full-time employees and covered individuals. This update clarifies how Applicable Large Employers (ALEs) can meet their Affordable Care Act (ACA) reporting obligations while reducing administrative burdens.

Alternative Method for Furnishing Form 1095-C

Recent regulatory updates have given employers an alternative, less burdensome option for distributing Form 1095-C to employees. Effective with the 2024 reporting year, employers are no longer required to automatically provide Form 1095-C. Instead, if an employer follows the required process, an employer can give notice of the availability of Form and provide it only if the employee requests a copy.

To comply with this new option, employers must notify employees of their right to request Form 1095-C. This notification must be clear, conspicuous, and easily accessible, which can be achieved by posting a notice on the company's website indicating that the form is available upon request.

Notice 2025-15 establishes a standardized posting method, referencing the existing requirements for Form 1095-B notices. Employers can satisfy their ACA reporting obligations by meeting these new criteria.

Employer Notice Requirements

Instead of distributing Form 1095-C automatically to all employees, employers can provide notice of the ability to request the form. To comply, employers must ensure their notice meets the following requirements:

1. Visibility and Accessibility
   • The notice must be posted by the furnishing deadline (which for the 2024 calendar year is March 3, 2025).
   • The notice must be posted in a location on the employer’s website that is easily accessible to full-time employees.
   • The posting must remain available until October 15 of the year following the reporting year.
2. Content of the Notice

   The notice must include key employer contact information to facilitate employee requests for Form 1095-C, including:

   • An email address where requests can be submitted.
   • A physical mailing address where requests can be sent.
   • A phone number for employees to ask questions about the notice and form availability.
3. Presentation Requirements
   • The notice must be written in plain, easy-to-understand language without technical jargon.
   • It should use a font size large enough to ensure employees notice and read the message.

What This Means for Employers

If an employer meets the “clear, conspicuous, and accessible” notice requirements outlined in Notice 2025-15, they are no longer required to automatically furnish Form 1095-C to all employees. Instead, the form only needs to be provided upon request.

For statements related to the 2024 calendar year, employers must post the required notice by March 3, 2025. If an employee requests a Form 1095-C, the employer must provide it by the later of 30 days after the request is received, or January 31 of the following year.

For employers who use the alternative posting method, HR teams should take proactive steps to ensure their website notice meets the updated IRS criteria. They must establish a process for handling employee requests for Form 1095-C in a timely manner and educate employees on how to request their form if needed.

Benefit Allocation Systems (BAS) provides best-in-class, online solutions for: Employee Benefits Enrollment; COBRA; Flexible Spending Accounts (FSAs); Health Reimbursement Accounts (HRAs); Leave of Absence Premium Billing (LOA); Affordable Care Act Record Keeping, Compliance & IRS Reporting (ACA); Group Insurance Premium Billing; Property & Casualty Premium Billing; and Payroll Integration.

MyEnroll360 can Integrate with any insurance carrier for enrollment eligibility management (e.g., Blue Cross, Blue Shield, Aetna, United Health Care, Kaiser, CIGNA and many others), and integrate with any payroll system for enrollment deduction management (e.g., Workday, ADP, Paylocity, PayCor, UKG, and many others).