ACA Forms 1095/4-C: To e-file or not to e-file with the IRS

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Do you print and mail your ACA 1095-Cs to the IRS? Or do you file them electronically? Be aware: the requirements for who can print and mail forms to the IRS rather than filing electronically (e-filing) may be changing.

Today’s e-file rule is: US employers may print and mail (rather than e-file) their 1094-C & 1095-Cs to the IRS if they have fewer than 250 1095-Cs.

On June 18, 2018, the IRS released a revenue bulletin (2018-25) that may affect your ability to print and mail forms to the IRS rather than e-file. The bulletin documents a proposed rule change to the “Filing Requirements for Information Returns Required on Magnetic Media (Electronically).” The regulations currently allow employers to consider only a particular form when determining whether that form must be filed electronically – in the case of ACA requirements, that form is the 1095-C. According to this bulletin, however “The proposed regulations would require that all information returns, regardless of type, be taken into account to determine whether a person meets the 250-return threshold and, therefore, must file the information returns electronically.” Thus, an employer with fewer than 250 1095-Cs may have to begin filing electronically in the future.

For a small employer that is filing forms manually today, this could provide a significant burden if they now have to electronically file “all information returns.” This includes (but is not limited to):

  • 1099-DIV
  • 1099-MISC
  • 1099-INT
  • W-2
  • 1095-C
  • 1095-B

The IRS allowed for a public comment time frame that ended on July 31st, 2018. To date, the IRS has not provided a final ruling and per an IRS Payroll Industry call on October 4th, 2018, employers should “follow the existing rules” in this regard for now. The American Payroll Association IRS Issues Committee encouraged the IRS to delay any file ruling until the 2019 reporting year is over because many employers currently filing in paper form would be challenged to get systems in places to allow for electronic filing of these forms in time to meet the various filing deadlines.

As a reminder, ACA filing requirements for 2018 forms are as follows:

January 31, 2019
Provide Form 1095-C to all ACA-defined, full-time employees

February 28, 2019
For paper filers: Mail transmittal, Form 1094-C and included 1095-Cs, to the IRS

April 1, 2019
For electronic filers: (Because March 31, 2019 is a Sunday), E-file Form 1094-C and included 1095-Cs with the IRS

As always, you can rely on Integrity Data to keep you abreast of ACA and other payroll compliance changes that may affect your organization. Follow our hashtag #ACAfluent on social media for the latest updates. We will be monitoring this proposed rule and update this article as the regulations are finalized. Also, know that we have many options for ACA compliance that include the ability to electronically file your ACA information returns. Please reach out to for more information.

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