2024 ACA Reporting Deadlines, Requirements, and Insights

By: Melissa Olson   December 12, 2023

With the end of the year approaching quickly, organizations must turn their attention to the reporting and furnishing requirements of the Affordable Care Act’s (ACA) Employer Shared Responsibility Provisions, commonly referred to as the Employer Mandate.

As we dive into the nitty-gritty of the ACA Employer Mandate in this post, know that we’re all in this together. We understand the anxiety and confusion that can accompany these regulations. RPI Consultants is here to help you navigate these treacherous waters.

Now, let’s take a look at ACA requirements, deadlines, a new regulation to adhere to for those that paper file, and how Infor solutions can help manage compliance and avoid daunting penalties.

What Does the ACA’s Employer Mandate Require?

The Employer Mandate is a component of the ACA that requires Applicable Large Employers, or organizations with 50 or more full-time and full-time equivalent employees to offer minimum essential coverage that is affordable and meets minimum value to full-time employees and their dependents.

Every year, organizations must report this information via 1095-C forms (and 1095-Bs if self-funded) to the IRS and select state governments, depending on where their workforce works. State and federal reporting requirements differ as do their deadlines for filing the necessary healthcare information.

Below are the major ACA reporting deadlines to note for the 2023 tax year, to be completed in 2024.

ACA Paper Filing Deadline

Large employers looking to paper file their ACA information for the 2023 tax year have until Thursday, February 28, 2024, to do so.

In the past, organizations could file up to 250 paper filings, but the threshold has been greatly reduced to encourage electronic submission, thanks to new legislation that passed earlier this year.

Now, organizations may only paper file if they have 10 or fewer 1095-C forms. The net of this new legislation is—if your organization paper filed in 2022, you need to make plans to file electronically for 2023.

Contact RPI Consultants if you need help implementing an electronic solution for submitting filings to the IRS.

ACA Electronic Filing Deadline

With the threshold for paper filing greatly reduced, organizations will need to adhere to electronic filing requirements going forward. For the 2023 tax year, organizations must submit their 1094-C and 1095-C forms to the IRS by Monday April 1, 2024.

The electronic ACA filing deadline usually lands on the last day of March each year, but March 31, 2024, is a Sunday, so employers will have the extra day to submit their ACA information by Monday, April 1, 2024.

ACA Furnishing Deadline

Historically, the deadline for distributing the 1095-Cs to employees was January 31, but the IRS always issued a 30-day extension, giving employers another month to comply. Late last year, the agency issued regulations that made the 30-day extension permanent.

However, because 2024 is a leap year, the extra day in February makes the deadline for furnishing ACA information to full-time employees Friday, March 1, 2024, instead of March 2.

Don’t overlook this seemingly minor detail, as failing to furnish on time can result in late fines from the IRS. Infor CloudSuite does contain resources for printing and issuing 1095-Cs to applicable full-time employees, but if you require additional assistance, RPI Consultants can work with you to identify an ACA compliance solution that actively monitors reporting deadlines like this one.

PCORI Fees Deadline

Organizations offering self-funded health insurance plans as well as health carriers will need to also comply with the Patient-Centered Outcomes Research Institute fees deadline. For the 2023 tax year, fees will need to be submitted by Wednesday, July 31, 2024.

Unsurprisingly, the fee amounts to be submitted for 2023 have increased. According to IRS Notice 2023-70, the agency makes clear that plan years ending on or after October 1, 2023, and before October 1, 2024, the fee is $3.22 per person.

For plan years that ended on or after October 1, 2022, and before October 1, 2023, the fee is $3.00 per person.

State ACA Reporting Deadlines

The deadlines above reflect the federal ACA reporting deadlines for the 2023 tax year, to be completed in 2024. In addition to the aforementioned due dates, California, Massachusetts, New Jersey, Rhode Island, and Washington D.C., also have reporting and furnishing requirements for organizations with operations in their jurisdictions.

It’s important to note that you are not exempt from state ACA reporting if your business primarily operates out of a state that isn’t listed above.

Employee location determines whether organizations are obligated to comply with additional ACA state reporting.

If your organization has just one employee filing taxes in a state that mandates ACA state reporting, you must file a report in accordance with that state’s laws. With the prevalence of remote work, this is applicable to more employers than ever.

To help you manage the federal and state reporting deadlines, please refer to the chart below:

2024 ACA Reporting Deadlines

Are There Penalties for Non-Compliance?

Yes. Large employers that fail to meet the deadlines mentioned above could receive penalties under IRC 6721/6722. The IRS issues these penalties via Letter 972CG and Letter 5005-A.

Beyond failing to file and furnish ACA information on time, the tax agency may also issue penalties for failing to comply with the ACA’s Employer Mandate. The IRS issues these ACA non-compliance penalties via Letter 226J.

ACA penalties can be difficult to contest if your organization isn’t documenting necessary data and benefits information. As we’ve previously discussed, employee data quality is critical for system migrations, and the same is true for compliance purposes, like that of the ACA. Remember that the “Good-Faith Relief” is also no longer valid. This option expired in 2021.

RPI Consultants can work with you to set up ACA administration within the Infor Benefits module to determine eligibility, send offers, track waives as well as capture enrollments.

ACA Reporting Assistance

ACA reporting for employers is now entering its tenth year, and yet organizations continue to struggle with the requirements. Understandably though, keeping up with requirements can feel like trying to hit a moving target. You finally get a handle on one set of rules, breathe a sigh of relief, and then, bam! Changes swoop in like clockwork. It’s like navigating through a maze where the walls keep shifting.

Infor CloudSuite’s Benefits Module, a component of CloudSuite GHR, streamlines ACA compliance management. It includes features for offering coverage, tracking employee enrollment, costs associated with benefits, and functionality for transmitting 1095-C information to the IRS.

For organizations, it’s a balancing act. You’re striving to provide quality healthcare benefits to your employees while grappling with this constantly changing compliance landscape. It’s a challenge that demands time, resources, and patience. If you need assistance navigating the ACA reporting requirements this year, contact RPI Consultants.

We can ensure that the year-end patches for ACA are working correctly within your benefits module as well as ensure that your system is operating as intended and able to transmit critical ACA filings to the IRS and state governments.

To learn more about how best to prepare for ACA reporting using Infor benefits module, listen to the RPI Tech Connect podcast episode with Principal HCM Consultant, Matt Slazak below.