The IRS has released Notice 2025-15 providing guidance on issuing certain health insurance coverage statements to individuals under provisions added to the law by the Paperwork Burden Reduction Act.

Purpose of the Notice

This notice addresses the alternative manner of furnishing certain health insurance coverage statements to individuals, as permitted by sections 6055(c)(3) (Reporting of Minimum Essential Coverage/Form 1095-B) and 6056(c)(3) (Reporting by Applicable Large Employers (ALEs)/Form 1095-C) of the Internal Revenue Code (Code), which were added by section 2 of the Paperwork Burden Reduction Act. These sections are effective for statements regarding returns required by sections 6055 and 6056 for calendar years after 2023.

Background

Section 6055: Requires entities providing minimum essential coverage to file annual information returns with the IRS, reporting information such as the identity of each covered individual and their coverage months. It also requires these entities to furnish each responsible individual with a statement containing the same information as the annual information return. Generally, the statement must be furnished on or before January 31 of the year following the calendar year for which the return was required. Treasury Regulation § 1.6055-1(g)(4) provides an automatic 30-day extension of time to furnish these statements.
Alternative Manner of Furnishing Statements under § 1.6055-1(g)(4)(ii)(B): If the individual shared responsibility payment amount under section 5000A(c) for the calendar year in which minimum essential coverage is provided is zero, the requirement to furnish the statement is satisfied if the reporting entity posts a clear and conspicuous notice on its website, accessible to all responsible individuals, stating that they may request a copy of their statement. The notice must be timely posted and retained on the website through October 15 of the year following the calendar year to which the statement relates. The reporting entity must furnish the statement to a requesting responsible individual within 30 days of the request.
Section 6056: Requires applicable large employers (ALEs) (generally those with 50 or more full-time employees, including full-time equivalent employees, in the previous year) to file annual information returns with the IRS related to the health insurance offered to their full-time employees. Each ALE must also furnish each full-time employee with a statement containing the same information included in the annual information return. Generally, the statement must be furnished on or before January 31 of the year following the calendar year for which the return was required. Treasury Regulation § 301.6056-1(g)(1) provides an automatic 30-day extension of time to furnish these statements.
Paperwork Burden Reduction Act: Adds sections 6055(c)(3) and 6056(c)(3) to the Code, effective for statements concerning returns required by sections 6055 and 6056 for calendar years after 2023. These provisions state that a person required to make a return under section 6055(a) or section 6056(a) is treated as timely furnishing the written statements required under section 6055(c)(1) or section 6056(c)(1) if the person provides clear, conspicuous, and accessible notice that any individual may request a copy of such statement and the copy is timely furnished. For this purpose, the statement is timely furnished if furnished to such individual not later than the later of January 31 of the year following the calendar year for which the return was required to be made or 30 days after the date of the request.

Guidance

Section 6055: A person providing minimum essential coverage required to furnish a statement under section 6055 may satisfy the alternative manner of furnishing the statement under section 6055(c) by complying with the requirements of Treas. Reg. § 1.6055-1(g)(4)(ii)(B)(1)-(3), regardless of whether the individual shared responsibility payment amount under section 5000A(c) for the calendar year in which minimum essential coverage is provided is zero. The person providing minimum essential coverage must post the notice described in Treas. Reg. § 1.6055-1(g)(4)(ii)(B)(1)-(3) by the due date for furnishing the statement, including the automatic 30-day extension. For example, for 2024 statements, the person providing minimum essential coverage must post the notice by March 3, 2025. A requested statement is timely furnished if furnished no later than the later of January 31 of the year following the calendar year for which the return was required or 30 days after the date of the request. A person providing minimum essential coverage may furnish the statement electronically pursuant to Treas. Reg. § 1.6055-2.
Section 6056: An ALE required to furnish a statement under section 6056 may satisfy the alternative manner of furnishing the statement under section 6056(c)(3) by complying with the requirements of Treas. Reg. § 1.6055-1(g)(4)(ii)(B)(1)-(3), regardless of whether the individual shared responsibility payment amount under section 5000A(c) for the calendar year in which minimum essential coverage is provided is zero, and by substituting "full-time employee" for "responsible individual" and "Form 1095-C, Employer-Provided Health Insurance Offer and Coverage" for "Form 1095-B, Health Coverage". The ALE must post the notice described in Treas. Reg. § 1.6055-1(g)(4)(ii)(B)(1)-(3) (with the relevant substitutions) by the due date for furnishing the statement, including the automatic 30-day extension. For example, for 2024 statements, the ALE must post the notice by March 3, 2025. A requested statement is timely furnished if furnished no later than the later of January 31 of the year following the calendar year for which the return was required or 30 days after the date of the request. An ALE may furnish the statement electronically pursuant to Treas. Reg. § 301.6056-2.

Effective Date

The notice is effective for statements required by section 6055 or section 6056 with respect to returns for calendar years after 2023.

Prepared with the assistance of NotebookLM.