The IRS has announced the production schedule for filing Affordable Care Act (ACA) 2022 information returns electronically through the ACA Information Returns (AIR) System, with the 2023 filing season beginning on January 13, 2023. The AIR System is used for filing Forms 1094/1095-B and 1094/1095-C. As a reminder, Forms 1094-B and 1095-B are filed by minimum essential coverage providers (such as health insurers and employers sponsoring self-insured health plans) to report coverage information in accordance with Code § 6055. Forms 1094-C and 1095-C are filed by applicable large employers (ALEs) to provide information that the IRS needs to administer employer shared responsibility penalties and eligibility for premium tax credits, as required under Code § 6056. For calendar year 2022, Forms 1094-B and 1094-C are required to be filed with the IRS by February 28, 2023, or March 31, 2023, if filing electronically (see our Checkpoint article). (Filers may extend these deadlines by application to the IRS using Form 8809.) Revised Publications 5258, 5164, 5165, and 5308 provide guidance for electronic filers.
EBIA Comment: The threshold for mandatory electronic filing with the IRS remains at 250 returns, applied separately to each type of return and to original and corrected returns. The IRS has proposed substantially expanding the threshold (see our Checkpoint article), reflecting statutory changes made by the Taxpayer First Act of 2019. It will be interesting to see if the proposal is finalized before the next filing season. For more information, see EBIA’s Health Care Reform manual at Sections XXVIII (“Shared Responsibility for Employers (Play or Pay Penalty Tax)”), XXXVI.C (“Information Reporting of Minimum Essential Coverage (Insurers and Employers That Self-Insure)”), and XXXVI.D (“Information Reporting of Employer-Sponsored Coverage (Applicable Large Employers)”). See also the recently updated EBIA’s Form 1094/1095 Workbook, including Section X (“Filing With the IRS”).
Contributing Editors: EBIA Staff
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