On December 10, 2024, the U.S. Senate passed HR 3797, which deals with an alternative manner of furnishing health insurance coverage statements to employees—specifically the 1095-C. (The 1095-C provides coverage information to employees regarding health insurance options offered by Applicable Large Employers).
Prior to this amendment, the 1095-C had to be furnished to each employee in hard copy format, with a due date that was permanently extended to an automatic 30-days beyond the January 31 due date, which for calendar year 2024 would be March 3, 2024. The new requirement states that an ALE normally required to furnish such statements would be allowed to furnish them in an alternate manner if they provide “clear, conspicuous and accessible notice” regarding how to request a copy and that notice must be provided “not later than the later of…” January 31 of the calendar year for which the return was required, or within 30 days of receiving the employee request.
The Paperwork Reduction Act legislation has been presented to the White House where President Biden is expected to sign with a deadline of December 20. This bill passed the House in June of 2023, and thus has an effective date that shall “apply to statements for calendar years after 2023.” The law will take effect upon the signature of the President. We will continue to monitor the situation for any changes to language or dates included in the bill. It will be important to watch states react to the federal law, as several states have their own reporting requirements. Stay tuned to this space for updates on both federal and state Affordable Care Act (ACA) reporting requirements.
The full language of the bill can be found here.