Mandatory Electronic Filing for ACA Returns Deadline: April 1, 2024

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The Affordable Care Act (ACA) requires certain employers to electronically report health plan coverage to the IRS under Code Sections 6055 and 6056. A recent law change mandates electronic reporting for entities with just 10 returns, starting in 2024.

Action Steps

Employers subject to ACA reporting rules should explore electronic filing options to meet the April 1, 2024, deadline. They can work with a third-party vendor or review the IRS' ACA Information Returns (AIR) Program page for guidance. The AIR Help Desk can be contacted for electronic filing support at 1.866.937.4130.

Electronic Reporting Requirement

Starting in 2024, employers filing at least 10 returns must file ACA returns electronically, including certain information returns. This applies to entities with fewer than 10 Form 1094 and 1095 filings, based on other information returns like Forms W-2 and 1099, and is done through the AIR Program. The IRS offers technical guidance on electronic reporting under Sections 6055 and 6056 via the AIR Program main page.

AIR Program Overview

The AIR Program is utilized by software developers, transmitters, and issuers for ACA information returns. In most cases, third-party vendors are used by issuers, employers, and reporting entities to file electronically with the IRS.

Electronic Reporting Process

Entities submitting electronic returns through the AIR Program must complete the following steps:

1. Register for IRS e-Services tools and apply for the ACA Transmitter Control Code (TCC).
2. Pass all relevant test scenarios, using approved software, to transmit information returns to the IRS.

Additional details and resources can be found on the IRS AIR Program main page.

Waiver Form Electronic Filing Requirement

To request a hardship waiver, submit Form 8508 to the IRS at least 45 days before the due date of returns. The first waiver request is automatically granted. If a waiver has been requested in the past, entities must include cost estimates or a written statement justifying their application. Criteria for waivers include financial hardship, catastrophic events, or technical limitations. Waivers must be reapplied for each tax year. Approved waivers should be kept for records. Failure to file electronically without a waiver may result in a penalty, but up to 10 returns can be filed on paper without penalty.

Filing Extension Requests

Reporting entitles can request an automatic 30-day extension by submitting Form 8809 to the IRS on or before the due date of the returns. No signature or explanation needed for the extension. The form can be submitted as a fill-in form or an electronic file.

Download the bulletin for more details.