Starting in 2024, significant changes are taking effect in the way employers file their Affordable Care Act (ACA) forms. These changes expand the electronic filing requirement to include more employers. In this article, we’ll explain the updated rules and how they impact businesses.
Electronic Filing Threshold: Prior to 2024, employers were only required to file ACA forms electronically if they were submitting 250 or more of a specific form, such as the Form 1095-C. However, the threshold has now been drastically reduced. Employers are now obligated to file their ACA forms electronically if they need to file at least 10 “information returns” during the calendar year.
Counting “Information Returns”: The definition of “information returns” is crucial to understand these new requirements. An “information return” includes various forms, such as the Form 1094 series, Form 1095-B, Form 1095-C, Form W-2, and the analogous forms for U.S. territories. It also encompasses the Form 1099 series. It’s essential to be aware of the forms that fall under this category.
Additional Reporting for Partnerships: Partnerships with more than 100 partners have a specific requirement – they must file their ACA forms electronically. This rule remains unchanged, and it’s vital for such partnerships to adhere to this requirement.
Electronic Reporting via the Affordable Care Act Information Returns System (AIR System): To facilitate electronic filing of ACA forms, the IRS has established the Affordable Care Act Information Returns System, known as the AIR System. Those responsible for filing ACA forms electronically on behalf of an employer must obtain an ID.me account and apply for a Transmitter Control Code. The deadline for electronically filing 2023 ACA forms is March 31, 2024, unless there’s guidance from the IRS indicating otherwise. For a detailed understanding of the reporting requirements and deadlines, employers new to electronic filing in 2024 are encouraged to reach out to their payroll vendor or gain access to the AIR System promptly.
Corrected ACA Forms: If an employer needs to file a corrected ACA form after January 1, 2024, they must follow the same format as the original filing. In other words, if the original form required electronic filing, any corresponding corrected form must also be submitted electronically. Conversely, if the original form was permitted to be filed on paper and was filed as such, any corrected form corresponding to it should be submitted on paper.
These changes in ACA form filing requirements have broad implications for employers, particularly those who were previously exempt from electronic filing. Understanding the new rules, counting “information returns,” and utilizing the AIR System for electronic filing is essential for compliance.
Brookshire Benefits is fully equipped to assist you in navigating these regulatory challenges. Whether you have questions or need support in meeting these requirements, we’re here for you. Our dedicated team is committed to guiding your organization through the evolving ACA filing landscape, ensuring compliance with these vital regulations. For additional information and resources, please don’t hesitate to contact us for more information. Learn More
