As employers, dealerships must comply with numerous reporting and disclosure requirements throughout the year in connection with their group health plans. Navigating compliance in this area can be difficult. PAA’s Insurance Department and Regional Managers can assist dealers with compliance questions and offer services and programs to minimize the Affordable Care Act’s compliance workload.

File Affordable Care Act (ACA) Forms 1094-C and 1095-C (paper filing deadline) - February 28,2026 or March 31, 2026 (Electronic filing deadline)

Applicable large employers (ALEs) must report information about their health plan coverage to the IRS using Forms 1094-C and 1095-C. Paper filing is now an option only for very small employers (i.e., employers that file fewer than 10 information returns during the year).

All electronic filed ACA reporting forms must be completed and submitted through the IRS Affordable Care Act Information Returns (AIR) system. (Affordable Care Act information returns (AIR) | Internal Revenue Service) The IRS advises this is generally not something that a typical employer could navigate on their own, without the support of an ACA reporting vendor.

1094-B and 1095-B - Non-ALEs with self-insured health plans must report information about their health plan coverage to the IRS using Forms 1094-B and 1095-B. The February 28 deadline applies only to filing paper versions of these forms; the deadline for electronic filing is March 31, 2026.

Affordable Care Act - Updates

On December 23, 2024, the Paperwork Burden Reduction Act (H.R. 3797) and the Employer Reporting Improvement Act (H.R. 3801) became law. Both laws now modify provisions under the Patient Protection and Affordable Care Act (the ACA) related to the 1095-B and 1095-C tax forms. Below are some key highlights:

· Employers are no longer required to send the 1095-B or 1095-C forms to covered individuals unless a form is requested and as long as the employer has notified covered individuals of their right to request a form. If a form is requested, it must be furnished by January 31, or 30 days after the date of the request, whichever is later. For the 2025 calendar year reporting, the January 31 deadline has been extended to March 2, 2026.

· Changes the IRS current practice of allowing an individual’s date of birth to be substituted for individual’s TIN if the TIN is not available.

· Changes the IRS practice of allowing employers to offer the forms to individuals electronically, if an individual affirmatively consented to receive the forms electronically at any time prior. An individual may revoke such prior consent in writing.

· Extends to 90 days the time for employers to respond after receiving their first Letter 226-J regarding a notice of proposed assessment.

· Implements a six-year statute of limitations for collecting penalty assessments.

Submit The Prescription Drug Data Collection Report For Group Health Plans And Health Insurance Issuers By June 1 Annually

A transparency law requires employer-sponsored health plans and health insurance issuers to report information about prescription drugs and health care spending to the federal government annually. This reporting process is referred to as the “prescription drug data collection” (or “RxDC report”). Most employers will rely on third parties, such as issuers, third-party administrators (TPAs) or pharmacy benefit managers (PBMs), to prepare and submit the RxDC report for their health plans.

Report and pay PCORI Fee for Employers with self-insured health plans and HRAs -July 31 annually

Employers with self-insured health plans, including HRAs, must pay an annual fee to fund the Patient-Centered Outcomes Research Institute (PCORI). Employers use IRS Form 720 to report and pay PCORI fees. Calculations on counting methods are different for self-funded plans versus HRA-only plans (counting exception provided if employers are both self-funded and have an HRA).

File Form 5500 for ERISA-covered group health plans that do not qualify for the small plan exemption - July 31 for Calendar Year Plans

Employers with ERISA-covered welfare benefit plans are required to file an annual Form 5500 unless a reporting exemption applies. The Form 5500 must be filed by the last day of the seventh month following the end of the plan year. For calendar-year plans, this deadline is July 31. Small health plans (fewer than 100 participants on first day of plan year) are generally exempt from the Form 5500 filing requirement.

Provide SAR for Group health plans that are subject to the Form 5500 filing requirement - September 30 for Calendar-Year Plans

Employers that must file a Form 5500 must also provide participants with a summary of the information in the Form 5500, called a summary annual report (SAR). The SAR must be provided within nine months of the close of the plan year. For calendar-year plans, this deadline is Sept. 30. Plans exempt from the annual 5500 filing requirement are not required to provide a SAR.

Medicare Part D Creditable Coverage Notices for Group health plans that provide prescription drug coverage to individuals eligible for Medicare Part D by October 15

Employers with group health plans that provide prescription drug coverage must notify Medicare Part D-eligible individuals by October 15 of each year about whether the drug coverage is at least as good as Medicare Part D coverage (in other words, whether their prescription drug coverage is “creditable” or “non-creditable”). In addition, all employers must self-certify that their RX plan is creditable (or non-creditable) on CMS’s website at the following address: https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosureForm.html. This must occur within 60 days after the beginning of each plan year.