There is some potential legislation pending presidential approval that could affect the Affordable Care Act (ACA) employer reporting requirements. It’s unclear if these bills will become law, but as we are amid filing season, wanted to share a summary of what we know:

Key Provisions of the Paperwork Reduction Act (PRA):

• Simplified Form Furnishing: Employers could meet furnishing requirements by providing employees with a notice that they can request a copy of Form 1095-B/C, which must be provided either by January 31 or within 30 days of the request.
• Effective Date: If passed, these changes would apply to forms for the calendar year 2024, due in 2025.
• E-File Requirement: Applicable Large Employers (ALEs) must continue to electronically file forms with the IRS.
• State-Specific Requirements: These provisions do not override any state-specific requirement

Key Provisions of the Employer Reporting Improvement Act (ERIA):

• Electronic Form Delivery: Employers can furnish Forms 1095-B/C electronically with employee consent.
• Alternate Information Use: Employers can use an individual’s date of birth instead of a Social Security Number for Form 1095-B/C reporting.
• This only applies if:
• SSN cannot be collected 
• And does not apply when:
• Reporting the employee on Form 1095-C
• And Form 1095-C for employees
• Extended Response Time: The response time for initial Employer Shared Responsibility Payment (ESRP) letters is extended to 90 days, effective from 2025 assessments. 
• Statute of Limitations (SOL): A 6-year SOL is established for the IRS to seek an ESRP, starting from the required filing date of Forms 1094-C and 1095-C.

Recommended Actions and Notes for Employers:

• These legislative updates simplify federal reporting processes and provide greater flexibility but do not impact state reporting obligations.
• Awareness of effective dates, adjusted timelines, and differing federal and state requirements is crucial to avoid penalties.
• The language relating to the notice to employees currently lacks guidelines; we will be keeping close for adjustments.
• These legislative updates simplify federal reporting processes and provide greater flexibility but do not impact state reporting obligations.
• Awareness of effective dates, adjusted timelines, and differing federal and state requirements is crucial to avoid penalties.
• The language relating to the notice to employees currently lacks guidelines; we will be keeping close for adjustments.



Should you have any questions or need further assistance, please do not hesitate to contact our support team @ infoabout@sync-stream.com

Disclaimer: SyncStream Solutions does not provide legal, regulatory or tax guidance, or advice. If legal advice counsel or representation is needed, the services of a legal professional should be sought. The information in this document is intended to provide a general overview of the topics and services contained herein. SyncStream Solutions makes no representation or warranty as to the accuracy or completeness of the document and undertakes no obligation to update or revise the document based upon new information or future changes.