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Posted

Hello all,

Due to an administrative mix-up a client did not file Forms 1095-C for 2023, but their insurer did file 1095-Bs. Client has not received a 5699. Do we just go ahead and file the delinquent 1095-Cs? What to do with the 1095-Bs? Any grace given there?

Thanks!

Posted

The Forms 1095-B were solely the carrier's responsibility and only addressing §6055 (MEC) reporting.  The §6056 (ER mandate) reporting is the component missed by the employer not providing/filing the Forms 1095-C, assuming the employer is an ALE.

So there is no action item for the 1095-B.  That was never the client's responsibility, and it appears it was handled properly regardless.

For the missed Forms 1095-C, the client will have to decide how to proceed.  We're past the timeframe for the standard reduced penalty relief (that ended 8/1).  If arguing for reasonable cause relief, filing asap will likely improve the chances of success.

Slide summary:

2024 Newfront ACA Employer Mandate & ACA Reporting Guide

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