1095C/1094C & 1095B/1094B Reporting & Filing
This is our annual reminder which you may receive or have already received from your Payroll provider, Accountant, Labor Attorney, etc. regarding the continued annual Form 1095-B or 1095-C delivery & filing requirements. The Affordable Care Act requires employers to prepare and provide certain forms depending on the employer size and type of health plan issued to employees:
- 2025 Form 1095-C: Applicable Large Employers (i.e. employers with 50 or more full-time + “full-time equivalent” employees in 2024, including members of an aggregated group or under common control) must furnish & deliver a 2025 Form 1095-C to all full-time employees (full-time as defined by ACA) whether they were enrolled in health coverage or not and who were employed for any period of time in the reporting year (2025). *See below regarding legislation on furnishing the forms.
- 2025 Form 1095-B: Employers that are not an ALE but that provide self-insured, partially self-insured or “level-funded” medical coverage to employees in 2025, must furnish & deliver a 2025 Form 1095-B to all employees enrolled for any period of time in the reporting year (2025) as well as to retirees and/or COBRA/State Continuation enrollees that had coverage for any period of time in the reporting year (2025). *See below regarding legislation on furnishing the forms.
- *The Paperwork Burden Reduction Act (signed into law 12/23/24) eases an employer’s requirements for providing 1095-C forms to participants. The Act allows employers to only furnish the form if requested by the participant. (This leeway had previously been granted on 1095-B forms) To use this method, the employer must provide a formal notice to participants that the 1095-B and/or 1095-C forms are available upon request. Then if requested, the employer must furnish the form by the later of: 1) March 1st, 2026; or 2) within 30 days after the request from the member. The employer still needs to file the forms with the IRS.
There are two deadlines for the forms:
- The deadline for filing the 1095-B or 1095-C (whichever is applicable) forms along with the 1094-B or 1094-C (whichever is applicable) Transmittal forms with the IRS is by March 2nd, 2026 if filed by paper or by March 31st, 2026 if filed electronically.
- The deadline for employers to provide notice of (and optionally provide) the Form 1095-B or 1095-C (whichever is applicable) to individuals is no later than March 2nd, 2026.
eFiling threshold requirement:
If filing more than 10 IRS forms, employers must efile with the IRS.
Hopefully, by now, you are familiar with this process since it has been around for years. For those employers that have grown in size and had become or continued to be an ALE in 2025 or had a self-insured, partially self-insured or “level-funded” medical plan in 2025, we wanted to bring this to your attention as a courtesy to you. Your Stumm Insurance Service Team can direct you to a vendor that can create the 1095-B or 1095-C forms for you. For more information, please contact your Stumm Insurance Service Team as soon as possible if you would like to discuss this solution.
What’s your group size?
Over many years, the Employee Benefits industry and Labor & Health insurance laws have created several “company size thresholds”, which should be monitored by employers and, in most cases, reported to their insurance carriers (as well as State & Federal governments). The specific size thresholds for many of these laws/requirements vary and the measurement/calculation of these thresholds also vary, so an employer needs to follow the “counting methodology” (can be current or prior calendar year or averages) for each law/requirement. The most common employee thresholds (and some applicable laws) to monitor:
- 10 employees – eFiling IRS returns or statements
- 15 employees – American with Disabilities Act, Pregnancy Discrimination Act, Genetic Information Nondiscrimination Act
- 20 employees – Medicare/Group health plan coordination, COBRA, Age Discrimination in Employment Act
- 50 employees – Family Medical Leave Act, Applicable Large Employer (ALE) determination, ACA 1095-C filing, health plan “Community rating” (small group) vs. “Experience rating” (large group) for certain states.
- 100 employees – Medicare/Group health plan coordination, EEO-1 reporting, 5500 filing, Medical Loss Ratio segment, health plan “Community rating” (small group) vs. “Experience rating” (large group) for certain states.
At the end of each year, and/or prior to their health insurance anniversary date, Employers (both stand-alone, and those aggregated with other employers under common control) should maintain an accurate monthly headcount of full-time & part-time employees, follow the applicable counting methodology, determine if any threshold has been crossed, and prepare to alert the insurance companies and/or employees of any changes.
Insurance Rebates & Premium Credits
Since 2011, fully insured medical carriers/plans have been subject to the Medical Loss Ratio (MLR) rules – and some have been required to deliver rebates to customers, resulting in employers determining if/how much of the rebates need to be reimbursed back to plan participants. Remember, ERISA law does require employers to utilize “returned plan assets” (i.e., these rebates and/or premium credits) for the benefit of the welfare benefit plan. In other words, the employer can retain the portion of the rebate/credit equal to the percentage they funded, while issuing the remaining portion to plan participants. Keep in mind that if your company receives a rebate check, your Stumm Insurance Service Team can assist you with the determination and calculation of any applicable rebates to your plan participants.
Crain’s Chicago Business, Best Places to Work 2025!
Stumm Insurance is proud to announce that our company was, once again, selected as one of the top 100 companies in Crain’s Chicago “Best Places to work” list in 2025! We are honored to be recognized, but truly acknowledge it is our employees that make working at Stumm Insurance such a positive experience. That positivity directly stems from working with all of you, our great clients, on a daily basis. So, we thank each and every one of you for helping us together achieve a spot on this esteemed list.
Upcoming Holidays
Please note that Stumm Insurance is “closed” on certain Holidays throughout the year. Your Stumm Insurance Service Team will not be readily available on these dates during this 1st quarter:
- 01/19/2026 Martin Luther King, Jr. Day
Should you have any questions or would like to discuss these or any other topics, please feel free to contact your Stumm Insurance Service Team.