2023 Updates for 1095-C Reporting Deadlines

2023 has officially begun, which means it is time to think about how and when you plan to furnish form 1095-C. 

Continue reading for a brief refresher on what form 1095-C entails as well as updated reporting deadlines for 2023. 

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Refresher: What Is Form 1095-C?

The Affordable Care Act (ACA) requires employers with 50 or more full-time equivalent employees to offer affordable healthcare coverage that meets the minimum value standard or potentially face a fine. The 1095-C form is the government’s way of tracking this. The primary function of form 1095-C is to communicate health insurance information to the IRS. 

All Applicable Large Employers (ALEs) must prove that they provided minimum essential coverage (MEC) to employees at an affordable rate. All other employers who provided self-insured plans must also report for their months of coverage. 

Form 1095-C includes information about the health insurance coverage that an individual’s employer offered and whether or not the employee enrolled in that coverage. The primary purpose of the 1095-C form is to communicate any health insurance information directly to the IRS.

How to File 1095-Cs with the IRS

Forms 1094-C and 1095-C may be filed through the mail or electronically (e-file). All Applicable Large Employers (ALEs) reporting on 250+ employees must e-file. Due to newly proposed regulations, beginning in the 2023 taxable year, only employers with 10 or fewer 1095-C forms will be able to paper file with the IRS.

While it is not a requirement, the IRS encourages employers to file electronically, even if they have fewer than 250 employees. The primary reason for this is to ensure safe delivery. 

When you submit your paper form 1095-C via the mail, you risk losing the form, seeing it stolen, or even sustaining damage. By sending your documents electronically, you ensure safe delivery. You can also count on the IRS to receive them more promptly. 

If you plan on mailing your IRS forms, keep the following tips in mind:

• Use First-Class Mail

• Do not fold forms (use flat mailing)

• Do not paper clip or staple the documents together

• If you're sending multiple forms, use conveniently-sized packages. If you do this, write your names, number the packages consecutively, and place form 1094-C in package number one.

Visit the IRS website for further detailed instructions on how to correctly e-file. 

1095-Cs Reporting Deadlines in 2023

Last year the IRS set a 30-day extension for furnishing form 1095-C to employees. That extension will also be available in 2023, as final regulations have established the extension as a permanent change. 

The extended due date for furnishing forms 1095-C to employees is March 2, 2023. The previous due date for this was January 31.

The due date for filing form 1094-C and all copies of 1095-C with the IRS is February 28 if mailing paper copies and March 31 if filing electronically.

What Is Form 1094-C?

While the 1095-C is distributed to employees, it is also distributed to the IRS. When organizations send form 1095-C to the IRS, they must also submit Form 1094-C. This form is not sent to employees and acts as a cover sheet for form 1095-C. 

What Are Forms 1095-A & 1095-B?

The filing requirements for businesses will depend on how the plan is insured. Some plans are self-insured, while others are fully insured. 

1095-A forms are distributed to people who received insurance through a federal or state marketplace. 1095-B forms are distributed to people who obtained insurance through small self-funded groups, employers who use the Small Business Health Options Program, or fully-insured employer-sponsored plans.

Where Do You Send Form 1095-C?

If you plan to send documents electronically, visit the IRS website for more detailed information. If information is unavailable, check back later for updated instructions. 

Mailing requirements are as follows: 

If your principal business, office/agency, or legal residence (in the case of an individual) is located in:

Alabama, Arizona, Arkansas, Connecticut, Delaware, Florida, Georgia, Kentucky, Louisiana, Maine, Massachusetts, Mississippi, New Hampshire, New Jersey, New Mexico, New York, North Carolina, Ohio, Pennsylvania, Rhode Island, Texas, Vermont, Virginia, West Virginia

Mail to:

Department of the Treasury

Internal Revenue Service Center

Austin, TX 73301

If your principal business, office/agency, or legal residence (in the case of an individual) is located in:

Alaska, California, Colorado, District of Columbia, Hawaii, Idaho, Illinois, Indiana, Iowa, Kansas, Maryland, Michigan, Minnesota, Missouri, Montana, Nebraska, Nevada, North Dakota, Oklahoma, Oregon, South Carolina, South Dakota, Tennessee, Utah, Washington, Wisconsin, Wyoming

Mail to:

Department of the Treasury

Internal Revenue Service Center

P.O. Box 219256

Kansas City, MO 64121-9256

While mailing requirements are unlikely to change, please check the IRS website regularly for the most updated information. 

Additional Resources

You can also stay informed, educated, and up-to-date with form 1095-C and other important topics by using BerniePortal’s comprehensive resources:

• BernieU—free online HR courses, approved for SHRM and HRCI recertification credit

• BerniePortal Blog—a one-stop-shop for HR industry news

• HR Glossary—featuring the most common HR terms, acronyms, and compliance

• HR Guides—essential pillars covering an extensive list of comprehensive HR topics

• HR Party of One—our popular YouTube series and podcast, covering emerging HR trends and enduring HR topics