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2024 ACA Reporting: Draft Forms Now Available

Thursday, August 1, 2024
2024 ACA Reporting: Draft Forms Now Available
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The Internal Revenue Service (IRS) has issued the draft forms for 2024 reporting under Internal Revenue Code Sections 6055 and 6056. However, the draft instructions for these forms have not been released yet.

  • The 2024 draft Forms 1094-B and 1095-B are draft versions of forms that will be used by providers of minimum essential coverage—including self-insured plan sponsors that are not applicable large employers (ALEs)—to report under Section 6055.
  • The 2024 draft Forms 1094-C and 1095-C are draft versions of forms that will be used by ALEs to report under Section 6056 as well as for combined Section 6055 and 6056 reporting by ALEs that sponsor self-insured plans.

No major changes were made to the draft forms for 2024 reporting. However, certain changes may be made once the forms and instructions are finalized.

Electronic Filing Requirement

For information returns due on or after January 1, 2024, the electronic filing threshold has been lowered to 10 or more returns, down from the previous threshold of 250 returns. This 10-or-more requirement applies collectively to certain information returns. As a result, a reporting entity might need to electronically file fewer than 10 of Forms 1094 and 1095 but still be required to file electronically due to other types of information returns filed, such as Forms W-2 and 1099.

Electronic filing is done using the ACA Information Returns (AIR) Program. The IRS has provided a lot of guidance and information on electronic reporting under Section 6055 and Section 6056 through its AIR Program main page. However, this guidance is generally very technical and intended for software developers and other entities that plan on providing electronic reporting services. Nonetheless, it can provide useful information on standards and procedures for returns transmitted through the AIR Program.

 

Action Steps

Employers should become familiar with the draft forms for 2024 calendar year reporting, keeping in mind that these are draft versions only and should not be relied upon for filing. Employers should also monitor future developments for the release of 2024 draft instructions for these forms.

Additional IRS Resources

The IRS provides the following resources for reporting entities:

Important Dates

ACA information reporting for the 2024 calendar year is due in early 2025 as follows:

  • March 3, 2025 – Individual statements for 2024 must be furnished within 30 days of Jan. 31, 2025. An alternative method of furnishing Form 1095-B is available. Because the deadline falls on a weekend, the individual statements must be furnished by the next business day, which is March 3, 2025.
  • March 31, 2025 – Electronic IRS returns for 2024 must be filed by March 31, 2025.

Material posted on this website is for informational purposes only and does not constitute a legal opinion or medical advice. Contact your legal representative or medical professional for information specific to your legal or medical needs.