Forms 1094 & 1095: Forms, Instructions, & Deadlines
The Affordable Care Act requires applicable large employers (ALEs)—generally those with 50 or more full-time employees—to report information to the IRS and to their full-time employees about their compliance with the employer shared responsibility (pay or play) provisions and the health care coverage they have offered (or did not offer).
Self-insured, including level-funded, employers (regardless of size) have additional reporting responsibilities that apply to health coverage providers.
Forms & Instructions
The following Internal Revenue Service (IRS) forms and instructions are available for 2024 calendar year reporting:
- Minimum Essential Coverage (MEC) Reporting (Section 6055)
- Large Employer Reporting (Section 6056)
Deadlines
The following chart provides the information reporting due dates for 2024 calendar year reporting for ALEs (both fully-insured and self-insured), as well as for small-level funded employers that are not considered ALEs.
| Action | Fully-Insured ALEs | Self-Insured ALEs (Level Funded) | Level Funded Employers with Fewer Than 50 Full-Time Employees |
| Form 1095-C to Full-Time Employees | The Paperwork Burden Reduction Act (H.R. 3797) (“PBRA”), aims to ease the strain of this deadline requirement by providing the following: • Employers are no longer required to send employees a Form 1095-B or 1095-C, unless the employee requests a copy of the applicable form. •Notice of Availability. To take advantage of this new process, employers must provide a “clear, conspicuous, and accessible notice” to employees informing them that they can request a copy of the Form 1095-B or 1095-C. (The PBRA states that the IRS may publish regulations relating to the time and manner of this notice.) | The Paperwork Burden Reduction Act (H.R. 3797) (“PBRA”), aims to ease the strain of this deadline requirement by providing the following: • Employers are no longer required to send employees a Form 1095-B or 1095-C, unless the employee requests a copy of the applicable form. •Notice of Availability. To take advantage of this new process, employers must provide a “clear, conspicuous, and accessible notice” to employees informing them that they can request a copy of the Form 1095-B or 1095-C. (The PBRA states that the IRS may publish regulations relating to the time and manner of this notice.) | Not Applicable |
| Form 1095-B to Responsible Individuals (May be the primary insured, employee, former employee, or other related person named on the application) | Not Applicable | Review Paperwork Burden Reduction Act, as described above | March 3, 2025, if not using the alternative method of furnishing. Under this method, a reporting entity must post a clear and conspicuous notice on its website stating that responsible individuals may receive a copy of their statement upon request. |
| File Forms 1094-C & 1095-C with the IRS | March 31, 2025* | March 31, 2025* | Not Applicable |
| File Forms 1094-B & 1095-B with the IRS | Not Applicable | ALEs providing self-insured coverage to non-employees may use either the B series Forms or the C series Forms to report coverage for those individuals and other family members covered under the plan, by March 31, 2025* | March 31, 2025* |
*Beginning in 2024, reporting entities that file at least 10 returns during the calendar year must file electronically. Reporting entities must aggregate most information returns, such as Forms W-2 and 1099, to determine if they meet the 10-return threshold for mandatory electronic filing.
On December 11, 2024, Congress passed the Employer Reporting Improvement Act (H.R. 3801) (“ERIA”), which codifies certain IRS regulations designed to make ACA reporting easier for employers:
1. DOB May Substitute TIN—The ERIA codifies IRS guidance allowing employers to substitute an employee’s date of birth (“DOB”) for their Tax Identification Number (“TIN”) for purposes of ACA-related returns, if the employee’s TIN is unavailable.
2. Electronic Delivery of Requested Form—The ERIA also codifies the IRS’s electronic delivery rules with respect to Forms 1095-B and 1095-C, allowing employers to furnish those forms electronically to participants who consent to electronic delivery. The ERIA makes these changes effective for all statements with due dates after December 31, 2024.
Carrier Specific Information
The following carrier details help you navigate your specific carrier requirements.
| Carrier | Details |
| UnitedHealthcare | Fully Insured Groups: https://www.uhc.com/legal/irs-form-1095-b 1095-B will be produced for all UnitedHealthcare fully insured members and made available on member websites. A request for a paper form can be made. Level Funded Groups: Access the Mineral site to complete the ACA filing, including delivery of IRS Forms 1095-B and C to employees and the electronic transmissions (E-filing) to the IRS. |
| Dean Health Plan/Prevea360 | Dean Health Plan provides a report, and the group is responsible for the filing. Prevea360 will provide 1095-B only upon member request to generate. |
| Humana | Generates the 1095-B forms and submits 1094-B reporting to the IRS. All members can request or obtain a copy via Humana.com. |
| Network Health Plan | Sends the 1095-B reports to the members (including those on level-funded plans) and transmits this information to the government, including the 1094-B transmittal/cover letter. For the applicable large employer (51+FTE) they do not do the 1094/1095-C series. Network Health Plan will provide a group report upon request to assist with the completion of the form. |
| Robin HealthPartners | Posts reports on the Employer Portal by January 31st. They provide Form 1095- B to individuals who request them. |
| WPS | Providing forms 1094-B (transmittal to IRS) and 1095-B (sent to each covered member) for all fully insured and level-funded groups. Can provide Series C reporting upon request. |
| Anthem | Fully Insured Groups: Mails all the 1095-B forms to members directly starting in late January. They electronically file the 1094-B to the IRS on the group's behalf. Level Funded Groups: 1095s are placed on the employer portal to distribute to employees. |
Where do I go if I have questions?
Contact us today to speak with a member of your Forsite Benefits Advisory Team or your tax advisor if you have any questions.
Medicare Online Disclosure Reminder
The Centers for Medicare & Medicaid Services require plans to report their prescription drug coverage annually, no later than 60 days from the beginning of a plan year, within 30 days after termination of a prescription drug plan, or within 30 days after any change in creditable coverage status. For most plans, which renew on January 1st, the deadline for online reporting is March 1st.
For additional Medicare disclosure information, reach out to Forsite Benefits today.
DOL Increases Civil Penalty Amounts for 2025
The Department of Labor (DOL) has released its 2024 inflation-adjusted civil monetary penalties that may be assessed on employers for violations of a wide range of federal laws, including:
- The Fair Labor Standards Act (FLSA);
- The Employee Retirement Income Security Act (ERISA);
- The Family and Medical Leave Act (FMLA); and
- The Occupational Safety and Health Act (OSH Act).
The increased amounts apply to civil penalties that are assessed after Jan. 15, 2025 (for violations occurring after Nov. 2, 2015).
Key penalty increases include the following:
- The maximum penalty for violations of federal minimum wage or overtime requirements increases from $2,451 to $2,515 per violation.
- The maximum penalty for failing to file a Form 5500 for an employee benefit plan increases from $2,670 to $2,739 per day.
- The maximum penalty for violations of the poster requirement under the FMLA increases from $211 to $216 per offense.
The increased amounts apply to civil penalties that are assessed after Jan. 15, 2025 (for violations occurring after Nov. 2, 2015).
Takeaway
To minimize potential liability, employers should review their compliance with laws enforced by the DOL.
Employers should become familiar with the new penalty amounts and review their pay practices, benefit plan administration, and safety protocols to ensure compliance with federal requirements.
Employers may review the updated penalty amounts here. Reach out to us at assist@foresitebenefits.com for more resources.
Secure Your Spot for the First Great Culture Webinar of 2025!
We’re thrilled to announce that Motion Connected—Forsite’s sister company—is launching this year’s Great Culture Webinar Series with an exciting first episode! As a leader in employee engagement and wellbeing, this session will deliver valuable insights, engaging discussions, and actionable strategies to help organizations cultivate thriving workplace cultures.
Tune in as Alysia, an enthusiastic wellness champion with more than 14 years of experience in mental health and holistic wellness, reveals SNHU’s pioneering approaches to shaping a vibrant workplace culture. From innovative program design and holistic wellbeing initiatives to effective communication tactics, this webinar is essential for anyone seeking to enhance their organization’s culture.
Mark your calendar:
📅 Date: Wednesday, February 12th
⏰ Time: 11:00 AM CST
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Reserve your spot today; see you there!
Preventing Theft and Vandalism for Small Businesses
Theft and vandalism pose significant risks to small businesses across all industries. These incidents can lead to financial losses, property damage, and operational disruptions. Given these potential consequences, business leaders must take steps to safeguard their organizations.
Theft and vandalism can affect a small business’s finances and operations, so business leaders should take steps to proactively mitigate these risks.
This article explores the risks of theft and vandalism, prevention strategies, response protocols, and essential insurance considerations.
Understanding the Risks
Theft and vandalism manifest in various ways. For example, theft may involve shoplifting or employee dishonesty, while vandalism can include smash-and-grab incidents, graffiti, or property damage like broken windows. The risk of these crimes is growing; according to a July 2024 report from the Council on Criminal Justice, shoplifting rose 24% during the first half of 2024 compared to the first half of 2023. Repairing vandalism can cost thousands of dollars and disrupt business operations, further compounding financial losses and potentially harming a business’s reputation.
Prevention Strategies
To minimize the likelihood of theft occurring, employers should adopt robust prevention measures, such as the following:
- Establish anti-theft policies and effectively communicate them.
- Secure valuable items by storing them near registers or in locked cases.
- Thoroughly vet employees and have monitoring procedures in place.
- Train employees to identify suspicious behavior and respond appropriately.
- Ensure adequate staffing levels during high-risk times and engage customers proactively.
- Use technology like security cameras and motion detection lighting, as well as electronic identification tags for high-value items.
- Implement access controls, especially in areas with high-value goods.
- Use signage that publicizes the consequences of stealing.
Strategies to prevent vandalism include:
- Install physical deterrents, including fences, durable materials like impact-resistant glass, proper lighting, and strong locks and doors.
- Strengthen community ties by organizing a business watch program and collaborating with law enforcement.
Responding to Incidents
In the immediate aftermath of a theft or vandalism incident, employers should notify the proper authorities, document the damage, and file an insurance claim. They should then clean up to resume operations and minimize disruptions, analyze what went wrong, and update security measures accordingly.
Insurance Considerations
Having adequate insurance coverage is vital to reducing the financial impact of theft and vandalism. Policies such as commercial property insurance and business interruption insurance can cover clean-up costs, stolen items, property damage, and operational downtime. It’s important to work with a licensed professional to assess a business’s needs and secure appropriate coverage.
All small businesses face the risks of theft and vandalism. Taking proactive steps to prevent these incidents from occurring and mitigate their impacts is crucial to protect your business and its finances. Contact us today for more information.
Telehealth Exception has Expired for Calendar-Year HDHP/HSA Plans
In response to the COVID-19 pandemic, the U.S. Congress enacted legislation that temporarily allowed high deductible health plans (HDHPs) to provide benefits for telehealth services before plan deductibles were met. This relief became effective in 2020 and was repeatedly extended. It currently applies to plan years beginning before Jan. 1, 2025. This means the relief ended on Dec. 31, 2024, for HDHPs with the calendar year as their plan year.
As background, to be eligible for health savings account (HSA) contributions, individuals cannot be covered by a health plan that provides benefits, except preventive care benefits, before the minimum HDHP deductible is satisfied for the year. Generally, individuals who are covered by telehealth programs that provide free or reduced-cost medical benefits are not eligible for HSA contributions. However, due to the pandemic-related relief, HDHPs have been able to waive the deductible for telehealth services without jeopardizing individuals’ HSA eligibility.
Starting in 2025, providing telemedicine benefits other than just preventive care at no cost (or low cost) to participants makes them ineligible for HSA contributions. There has been bipartisan support to extend telemedicine relief for HDHPs either permanently or temporarily; however, Congress failed to extend this relief at the end of 2024. It remains to be seen if Congress will revive this relief in 2025.
Action Steps
Employers with HDHPs should review their health plan’s coverage of telehealth services to determine if changes should be made for the plan year beginning in 2025. For plan years beginning in 2025, the minimum HDHP deductible is $1,650 for self-only coverage and $3,300 for family coverage. Any changes to telehealth coverage should be communicated to plan participants through an updated summary plan description or a summary of material modifications.
Key Drivers of Rising Health Care Costs in 2025
Health care costs are projected to increase substantially in 2025. Estimates show a similar growth in spending as in 2024, marking multiple years of compounding costs.
According to industry surveys and reports, employers anticipate health care costs to increase between 7% and 8% in 2025.
As 2025 begins, many small business owners who offer group health insurance to employees remain curious about what is driving these increases. The following are key factors that will impact rising health care costs.
GLP-1 Drugs
Although initially approved as Type 2 diabetes treatments, glucagon-like peptide-1 (GLP-1) drugs have been found to be effective for weight loss when paired with diet and exercise. GLP-1 drug use for weight loss is already widespread but is expected to increase in popularity. GLP-1 medications typically cost around $1,000 per month. These costly medications are intended to be taken in perpetuity to achieve their benefits. This means that GLP-1 users must use these high-cost treatments on an ongoing basis to experience health benefits.
Cell and Gene Therapies (CGT)
CGT is designed to treat conditions like blood and lung cancer, sickle cell anemia, and spinal muscular atrophy. These therapies demonstrate significant medical advancement but come with a high price tag. In 2025, it’s estimated that nearly 100,000 patients in the United States will be eligible for CGT, which could cost $25 billion.
Chronic Health Conditions
Around 90% of U.S. health care spending is on people with chronic and mental health conditions. Chronic conditions include heart disease, stroke, cancer, diabetes, arthritis, and obesity. Chronic disease is increasing in prevalence in the United States and is projected to continue to do so in 2025 and the upcoming decades.
Aging Populations
Due to increasing life expectancy and decreasing birth rates, the percentage of the U.S. population that is 65 or older continues to rise. Per-person personal health care spending for this population is around five times higher than spending per child and almost 2.5 times the spending per working-age person.
Health Care Labor Costs
The current supply of health care workers does not meet the growing demand for utilization. This shortage is due to factors such as rising health care demands, an aging population, retiring workforces, and not enough talent entering the health care industry.
Employer Takeaway
Offering quality health care to employees carries a significant financial cost for organizations, comprising a substantial part of an overall budget. It’s more than just organizations that pay the price for growing health care costs; such expenses are often shared between employers and employees.
Rising health care costs may be unavoidable, but informed employers can better understand these trends and act appropriately. Contact us today for more resources on health care costs. Contact us today for more resources.