Credit: Allison Bell/ALM

The Internal Revenue Service has started to implement the Paperwork Burden Reduction, a new law that could make it easier for employers and their benefits advisors to meet Affordable Care Act health coverage annual statement requirements.

The IRS is giving employers advice about how to use the new coverage statement simplification law in Notice 2025-15.

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The new law, which has already taken effect, lets employers skip sending coverage statements to all full-time employees.

Related: Two employer health coverage reporting bills become law

Instead of sending a barrage of complicated, personalized coverage statements, an employer can put a "clear, conspicuous and accessible notice" on its website stating that coverage statements are available upon request.

When employers do send coverage statements, they can now choose to send the statements electronically. When an employee asks for a coverage statement, the employer is supposed to send the statement within 30 days.

The law applies to the statements for 2024 coverage that employers might be preparing now. The deadline for the forms for 2024 coverage is March 3.

The new law also codifies existing IRS regulations that let employers make the coverage statement available to part-time workers, seasonal workers and temporary workers only if those workers asked for the statement, according to an analysis posted by Hall Benefits Law.

In the new notice, IRS officials say the rules based on the new law will be similar to the existing coverage statement relief regulations, except that the new rules will also apply to full-time employees.

What it means: The new notice implements a law created by a bill introduced by a Republican lawmaker — Rep. Jason Smith, R-Mo. — but signed by former President Joe Biden.

The new notice appears to be the first effort by Trump's IRS to move ahead with implementation of a Biden-era law. This notice and future documents related to the Paperwork Burden Reduction Act could provide early hints about how the administration will implement other laws.

The backdrop: The IRS created an extensive coverage reporting system to support the ACA premium tax credit subsidy program and an "employer shared responsibility" coverage mandate.

Sending the statements helps employers show that they have offered employees "minimum essential coverage," or major medical coverage, with a minimum value, and need not pay penalties.

The coverage statement rules are complicated.

Employers could send the statements out using Form 1095-B or Form 1095-C.

Employers must use Form 1095-B if they have fewer than 50 full-time employees, are not "applicable large employers," are not subject to the employer coverage mandate, and have used a self-insured health plan to provide minimum essential coverage to employees.

A big employer may use Form 1095-B if it provides health coverage for independent contractors or other non-employees through a self-insured health plans.

Big, "applicable large employers" that are subject to the employer coverage requirements send statements using Form 1095-C.

The new coverage statement simplication rules apply to both Form 1095-B coverage statements and Form 1095-C coverage statements.and

Over the years, employers and others have found that workers have less need for paper coverage statements, in part because of the elimination of the ACA "individual coverage mandate," or effort to make individuals who fail to have minimum essential coverage pay a penalty.

The ERISA Industry Committee has been one of the groups asking the IRS to take steps to lighten the ACA statement burden.

The future: Although the new law should reduce employers' ACA coverage statement volume, employers and their benefits advisors should continue to talk to their ACA compliance advisors, according to Lisa Rippey and Stephanie Schmid, benefits law specialists at Stinson.

Some states have their own individual health coverage mandate requirements and may still want to see paper coverage statements, Rippey and Schmid write.

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Allison Bell

Allison Bell, a senior reporter at ThinkAdvisor and BenefitsPRO, previously was an associate editor at National Underwriter Life & Health. She has a bachelor's degree in economics from Washington University in St. Louis and a master's degree in journalism from the Medill School of Journalism at Northwestern University. She can be reached through X at @Think_Allison.