Compliance News Week Ending October 4, 2024

In this Article:

1094/1095B Forms and Instructions from IRS

1094/1095C Forms and Instructions from IRS

The IRS released the draft instructions for 2024 forms used by applicable large employers (50 or more FTEs) to report offer of coverage information for all full-time employees as well as the forms used by employers to report coverage under self-funded or level-funded plans. The draft instructions confirm that copies of Form 1095s must be delivered to full-time employees and covered individuals by March 3, 2025 and the Form 1094 and all Form 1095s must be submitted electronically to the IRS by March 31, 2025.

Draft 1094/1095B Forms and Instructions from IRS

The 1094/1095B forms would be completed by the carriers (no matter the size of the employer) and distributed to employees and submitted to the IRS. These forms would also be completed by self-funded/level funded group health plans that have less than 50 FTEs. These forms would also be used by employers offering an Individual Coverage Health Reimbursement Arrangement (ICHRA).

Draft 1094/1095C Forms and Instructions from IRS

The 1094/1095s forms would be completed by the Applicable Large Employers (ALE) and distributed to employees and submitted to the IRS. This would need to be completed by ALEs, with 50+ Full Time Equivalents (FTEs), offering fully insured health benefits or self-funded/level funded health benefits. These forms would also be used by employers offering an Individual Coverage Health Reimbursement Arrangement (ICHRA).

Resources

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