Simplified health coverage reporting

A recent Internal Revenue Service ("IRS") Notice provides employers and plan sponsors with administrative relief from certain distribution and reporting obligations associated with their employer-sponsored health plan coverage. Specifically, IRS Notice 2025-15 introduces new guidelines for the electronic furnishing of health plan coverage statements, aiming to reduce paperwork and streamline processes for both providers and recipients. This notice builds on the general requirements of the Affordable Care Act ("ACA") for furnishing Forms 1095-C (Employer-Provided Health Insurance Offer and Coverage), which is used by applicable large employers ("ALEs") to report health plan coverage offered to their employees.

Under the ACA, ALEs (generally, employers with 50 or more full-time employees, including full-time equivalent employees) are required to file annual information returns with the IRS and furnish Forms 1095-C to each full-time employee. This form provides details about the health plan coverage offered to the employee, including whether the coverage meets affordability and minimum essential coverage requirements.

With the guidance provided under IRS Notice 2025-15, ALEs generally no longer need to send Forms 1095-C to employees and covered individuals, unless the form is requested. To take advantage of this new rule, ALEs must provide employees and covered individuals clear and conspicuous notice of their right to receive a copy of the Form 1095-C. The notice must (1) be placed in a location on the employer's website that is reasonably accessible to all impacted individuals, (2) state that individuals can receive a copy of the Form 1095-C upon request and explain the process for making such request, and (3) include contact information to make the request and follow-up regarding any questions. For the 2024 calendar year, the notice was required to be posted by March 3, 2025, so employers will likely utilize this new process for 2025 calendar year filings and beyond.

The alternative method of posting notice and furnishing statements electronically represents a significant step towards modernizing the reporting of health plan coverage statements. Employers and plan sponsors with questions or concerns about ACA requirements should contact a member of Honigman's Employee Benefits and Executive Compensation Group for more information.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Alexander J. Burridge, Samantha A. Kopacz and S. Tony Ling of Honigman (c) Mondaq Ltd, 2025

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