The Internal Revenue Service (IRS) has begun the process of implementing the Paperwork Burden Reduction Act, a law from the Biden administration that is already in effect. To assist employers, the IRS has issued Notice 2025-15, which no longer requires employers to send coverage statements to all full-time employees.
Instead of sending out complex, personalized statements to full-time employees, employers now can post a “clear, conspicuous, and accessible” notice on their websites stating that coverage statements are available to employees upon request. If employees request a copy of their coverage statement, employers must provide the statement electronically within 30 days of the request. Additionally, employers may only make coverage statements available to part-time, seasonal, and temporary workers upon request.
The guidance applies to the coverage statements that employers prepared for 2024. The current deadline for employers to provide the 2024 forms was March 3, 2025.
The DOL guidance constitutes the Trump administration’s first effort to implement a law passed during the Biden administration. How Trump’s DOL handles guidance on the rule could indicate how it will implement other laws.
When Congress passed the Affordable Care Act (ACA), the IRS implemented a complicated coverage reporting system to support the premium tax subsidy program and shared coverage mandate for employers. Coverage statements show how employers have offered employees “minimum essential coverage,” or major medical insurance with a minimum value, and avoid the assessment of penalties.
The law requires employers to use either Form 1095-B or 1095-C to send out coverage statements to employees. Employers must use Form 1095-B if they meet all the following requirements:
- They have fewer than 50 full-time employees.
- They do not qualify as “applicable large employers.”
- They are not subject to the employer coverage mandate.
- They use a self-insured health plan to provide minimum essential coverage to employees.
However, a big employer may use Form 1095-B if it maintains a self-insured health plan that provides health coverage for independent contractors or other non-employees. Otherwise, big or “applicable large employers” subject to these requirements must use Form 1095-C to send coverage statements.
The guidance outlined in Notice 2025-15 applies to both Form 1095-B and 1095-C coverage statements. Employers have found in recent years that workers have less need for hard copies of their coverage statements, partially due to the elimination of the ACA “individual coverage mandate.” That mandate assessed penalties on those individuals who had no minimum essential coverage.
Although Notice 2025-15 should simplify employers’ obligations to provide coverage statements to employees, employers still should ensure they meet all requirements to remain compliant with the ACA. Furthermore, some states have individual health coverage mandate requirements, including providing physical coverage statements to employees.
HBL has experience in all areas of benefits and employment law, offering a comprehensive solution to all your business benefits and HR/employment needs. We help ensure you are in compliance with the complex requirements of ERISA and the IRS code, as well as those laws that impact you and your employees. Together, we reduce your exposure to potential legal or financial penalties. Learn more by calling 470-571-1007.
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