Jan 11, 2024
Amwins Connect January 2024 QOTM – Providing 1095 Statements Electronically to Employees
Question: I am an ALE (applicable large employer). Am I able to distribute the 1095-C statements to my employees electronically?
Answer: Yes. ALEs must furnish the Forms 1095-C to employees (in 2024 for the 2023 calendar year) no later than March 1, 2024. However, in order to do this properly, the employer must obtain the employee’s affirmative consent stating they do agree to receive the Form 1095-C electronically. This must be accomplished either by having the employee consent on paper form or in an email. The employer must then be careful to maintain these consents on file if they do distribute any Form 1095 (B or C) electronically.
This information is specifically noted in the Instructions on the IRS website.
'Consent to furnish statement electronically. An ALE Member is required to obtain affirmative consent to furnish a statement electronically. This requirement ensures that statements are furnished electronically only to individuals who are able to access them. The consent must relate specifically to receiving the Form 1095-C electronically. An individual may consent on paper or electronically, such as by email. If consent is on paper, the individual must confirm the consent electronically. A statement may be furnished electronically by email or by informing the individual how to access the statement on the ALE Member’s website. Statements reporting coverage and offers of coverage under an expatriate health plan, however, may be furnished electronically unless the recipient explicitly refuses to consent to receive the statement in an electronic format. Specific information on consents to furnish statements electronically can be found in Regulations section 301.6056-2'.
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