If you are an employer that sponsored an Individual Coverage Health Reimbursement Arrangement (ICHRA) during the 2021 calendar year, you are required to comply with the ACA annual filing requirements.  Even smaller employers must file.  The deadlines are approaching very soon!

THE CLOCK IS TICKING!!!!

For an ALE, the IRS requires reporting of ICHRAs for an applicable large employer (ALE) on Form 1095-C.  The 2021 Form 1095-C generally must be furnished to employees by March 2, 2022. The form, along with the transmittal Form 1094-C must be filed with the IRS by February 28, 2022 (if filed on paper) (and by March 31, 2022, if filed electronically).

For a non-ALE (small employer less than 50), the IRS requires reporting of ICHRAs for small employer ICHRA plans on Form 1095-B. The 2021 Form 1095-B generally must be furnished to employees by March 2, 2022.  The forms, along with the transmittal Form 1094-B must be filed with the IRS by February 28, 2022 (if filed on paper) (and by March 31, 2022, if filed electronically).

There are penalties for not filing and not filing timely.  Failure to file is not part of the good faith relief.

Please let us know if you have questions or would like assistance completing the forms.