The IRS has released Notice 2025-15, which provides guidance on the Paperwork Burden Reduction Act provisions on how employers and insurers can satisfy the alternative manner of furnishing Forms 1095-B and 1095-C (health insurance coverage statements to individuals). As background, applicable large employers (ALEs) and insurers that provide minimum essential coverage (MEC) are required to annually report information for each covered individual to the IRS and provide Forms 1095-B and 1095-C (statements showing proof of MEC). The Paperwork Burden Reduction Act provides that employers and insurers are no longer required to automatically furnish Forms 1095-B and 1095-C to individuals, unless the forms are requested, so long as timely notice is provided. Additional guidance was needed from the IRS on how to satisfy the notice requirement.
Notice 2025-15 provides guidance on the notice requirement, clarifying that the existing alternative manner rule that applies to furnishing statements to certain individuals (other than full-time employees) applies to full-time employees as well. Specifically, the notice must be posted on the employer or insurer website clearly and conspicuously with a statement that individuals may receive a copy of their forms upon request and must include an email address, a physical address, and a telephone number that individuals can contact if they have questions. The notice must be posted by the due date for furnishing the statement, including the automatic 30-day extension. For example, for 2024 statements, the person providing minimum essential coverage must post the notice by March 3, 2025. If requested, the statement must be provided by the later of January 31 of the year following the year to which the form relates, or 30 days after request. So, for example, an employee who requests a copy of Form 1095-C in July 2025 must be furnished a copy of the 2024 Form 1095-C within 30 days, but would not be entitled to receive the 2025 Form 1095-C until January 31, 2026. The alternative manner rule for the Forms 1095-C requires substituting “full-time employee” for “responsible individual” and “Form 1095-C, Employer-Provided Health Insurance Offer and Coverage” for “Form 1095-B, Health Coverage.”
EBIA Comment: Employers and insurers will want to familiarize themselves with the guidance and begin steps to establish any necessary process changes. While Notice 2025-15 provides clarity on the time and manner of the notice, it may be difficult to take advantage of the alternative method (for full-time employees) given that the legislation was issued in late 2024, and 2024 statements are due to full-time employees by March 3, 2025. For more information, see EBIA’s Health Care Reform manual at Sections XXVIII (“Shared Responsibility for Employers (Play or Pay Penalty Tax)”), XXXVI.C (“Information Reporting of Minimum Essential Coverage (Insurers and Employers That Self-Insure)”), and XXXVI.D (“Information Reporting of Employer-Sponsored Coverage (Applicable Large Employers)”). See also EBIA’s Form 1094/1095 Workbook at Sections IX (“Furnishing Employee Statements”), X (“Filing With the IRS”), and XV (“Penalty Assessment”).
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