Staying Ahead of the ACA Curve

The regulatory landscape of the Affordable Care Act (ACA) is evolving, placing increased pressure on Applicable Large Employers (ALEs) and benefits brokers to stay proactive—not just compliant. With the IRS extending the 1095-C furnishing deadline to October 15, 2025, employers now face heightened responsibility for ensuring employees receive timely and accurate information.

Though this change may seem minor, its implications are far-reaching. From IRS penalties (like Letter 226J) to conflicting state mandates and compressed timelines, ACA reporting is now a year-round obligation.

At ACA Compliance Solution Services, Inc., we understand that compliance isn’t just about filing—it’s about protecting your organization. This article outlines what’s changing, why it matters, and how we help thousands of employers and brokers reduce risk and stay audit-ready.

What’s Changing in 2025/2026: A New Furnishing Option

Beginning March 3, 2025, ALEs may furnish Form 1095-C only upon employee request—but only if a clear, accessible notice is posted on the employer’s website and remains available through October 15, 2025.

The notice must:

1. State that Form 1095-C is available upon request
2. Explain how employees can request it
3. Include employer contact information

This optional approach eases mailing burdens but introduces new technical and legal complexities. For organizations with large employee populations—or brokers managing multiple clients—tracking requests, maintaining website compliance, and managing overlapping state and federal requirements can quickly become overwhelming.

Importantly,California, New Jersey, Rhode Island, and the District of Columbia still require direct delivery of Form 1095-C to employees—regardless of federal policy.

Why Accuracy Matters More Than Ever

Even small errors—broken links, vague instructions, or late filings—can trigger IRS penalties under IRC Sections 6721/6722 and result in notices like Letter 226J, CP215, or 5699.

Simply posting a notice is not enough—it must be accurate, visible, and maintained throughout the compliance window.

The ACA Compliance Solution Services Advantage

We offer a full-service, compliance-first approach that protects your business and simplifies ACA obligations:

1. Complete Filing & Furnishing

   We manage the entire ACA reporting process, including preparing and filing Forms 1094-C and 1095-C with the IRS and applicable states. Our systems are always updated to align with the latest IRS and state mandates.



2. IRS Penalty Response & Reduction

   Our team handles IRS letters (226J, 5699, CP215), responds on your behalf, and works to reduce or eliminate penalties through our Penalty Reduction Services.



3. Data Reconciliation & Accuracy Audits

   We conduct proactive reviews to catch misclassifications, affordability errors, and missing safe harbor codes before the IRS does.



4. State Mandate Compliance

   We manage filings for all states with individual mandates, ensuring full compliance without burdening your internal teams.

Final Thoughts: Don’t Let ACA Compliance Become a Liability

As ACA rules grow more decentralized and complex, the cost of noncompliance rises. A single oversight—missed request, incorrect code, or missed filing—can result in tens of thousands of dollars in penalties and administrative disruption.

At ACA Compliance Solution Services, Inc., we combine legal expertise, smart automation, and hands-on support to give you confidence in your compliance process.

If you're a large employer, administrator, or broker seeking a trusted compliance partner, we’re here to build a tailored solution that reduces risk and saves time.

Call: (877) 959‑3953 x222
 Visit: www.acacss.com
Request your complimentary ACA compliance assessment

Let us handle the complexity—so you can focus on leading your organization.

FAQs

Q1 – What is the IRS 1095‑C furnishing notice requirement?

As of March 3, 2025, employers may furnish 1095-C forms only upon employee request if a website notice is posted and remains live through October 15. Without this notice, forms must be mailed or electronically delivered to all employees.

Q2 – Are IRS filings still required?

Yes. Employers must still file Forms 1094-C and 1095-C with the IRS by March 31, regardless of furnishing method.

Q3 – What about state mandates?

California, New Jersey, Rhode Island, and D.C. require direct delivery of 1095-C forms, even if the federal "furnish-on-request" method is used.

Q4 – What if we miss a deadline or make a mistake?

You could face serious penalties. We offer penalty mitigation, audit defense, corrections, and retroactive remediation.

Q5 – How can brokers leverage your services?

We offer broker-specific support, including scalable pricing, revenue-sharing options, and integration with client workflows—helping you offer seamless compliance to your clients.