In early February of this year, FNA Insurance Services reported that Congress had changed the rules surrounding the reporting of certain information under the Affordable Care Act (ACA). One of the major pieces of those rule changes was the conversion of 1095 delivery to electronic communication. This would provide significant administrative relief to employers when having to perform their annual Affordable Care Act obligations. The IRS promised to provide more concrete guidance in the future. You can read the full article HERE.

Recently, the IRS has released Notice 2025-15. This Notice contains promised guidance for employers wishing to ease their ACA administrative burdens. The Guidance states that the ACA reporting requirements for 1095s are satisfied if the employer provides “clear and conspicuous notice” on its website stating that an employee may receive their 1095 form upon request. In addition, employers must follow these guidelines:

- The online notice must be maintained by the employer and must be kept on the website until at least October 15 of the plan year;

- The online notice must be accessible to all employees (following state and federal website accessibility guidelines);

- The online notice must be available to employees by the date that their Forms 1095 would normally be due to them (including any extensions); and

- Employers have 30 days to furnish a physical copy of a 1095 form to an employee upon request

Employers who wish to take advantage of this new guidance should begin optimizing their website with a re-direct to the 1095 document database on the site’s home page. Future annual plan documents should include communication explaining the location of the Forms and how to access them. Employers should also have a process for quickly and efficiently retrieving an employee’s Form 1095 upon the employee’s request without unnecessary delays.

You can read the entire IRS document HERE.