Regardless of your size, if you are an employer that sponsored an Individual Coverage Health Reimbursement Arrangement (ICHRA) during the 2022 calendar year, you are required to comply with the ACA annual filing requirements. Compliance consists of (1) distributing notices to persons who received coverage during 2022, and (2) filing the same information with the IRS.
♦ The deadlines approaching very soon! ♦
For Employers that are ALEs
For an applicable large employer (ALE), the IRS requires reporting for ICHRAs be accomplished by completing IRS Forms 1094/1095-C.
To Covered Persons. IRS Form 1095-C generally must be furnished to employees and certain others who were covered during 2022 by March 2, 2023.
To the IRS. Copies of all the IRS Forms 1095-C, along with the transmittal IRS Form 1094-C, must be filed with the IRS by February 28, 2023 (if filed on paper) or by March 31, 2023 (if filed electronically).
For Employers that are not ALEs
For a non-ALE (small employer less than 50), the IRS requires reporting for ICHRAs for small employer ICHRA be accomplished by completing IRS Forms 1094/1095-B.
To Covered Persons. IRS Form 1095-B generally must be furnished to employees and certain others who were covered during 2022 by March 2, 2023.
To the IRS. Copies of all the IRS Forms 1095-B, along with the transmittal IRS Form 1094-B, must be filed with the IRS by February 28, 2023 (if filed on paper) or by March 31, 2023 (if filed electronically).
IMPORTANT: There are per day penalties for not filing and for not filing timely. These penalties are independent from whether a penalty regarding coverage is owed.
Please let us know if you have questions or would like assistance completing the forms.