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On Friday, Feb. 21, the U.S. Internal Revenue Service (IRS) issued a notice that explains an alternative method for “applicable large employers” (ALEs) to provide health coverage statements under IRS Code Sections 6055 and 6056.
IRS Notice 2025-15 is a deliverable of the Paperwork Burden Reduction Act, which was signed into law in December 2024 and allows certain employers to meet Form 1095 (Employer-Provided Health Insurance Offer and Coverage) distribution requirements for the 2024 reporting year by posting a notice of availability and then only distributing that information (electronically or via mail) upon request.
The IRS notice provides further detail on how to satisfy the requirements and gives a March 3 posting deadline for the 2024 reporting year.
Background on the Related Codes
IRS Code Section 6055 requires providers of minimum essential coverage under the Affordable Care Act (ACA) to report coverage information by filing an information return with the IRS and furnishing a statement to individuals. The information primarily is used by the IRS to administer — and by individuals to show compliance with — the individual shared responsibility provision in Section 5000A.
Similarly, Code Section 6056 requires employers that are ALEs (generally those with 50 or more full-time employees) under the employer shared responsibility provisions to file:
- Information returns with the IRS about whether they offered health coverage to their full-time employees (and their dependents);
- And, if so, information about the offer of coverage.
ALEs must also provide a copy of the information to the employee.
The New Notice Guidance
Under Notice 2025-15, instead of automatically providing statements, reporting entities may post a clear and conspicuous information bulletin on their websites. Besides the general statement information, the bulletin also must notify individuals they may request a copy of their statement. This information must be posted by the original furnishing deadline, including any automatic 30-day extension, and must remain accessible through Oct.15 of the following year.
If a responsible individual or full-time employee requests a statement, the reporting entity must furnish it within 30 days of the request or by Jan. 31 of the following year, whichever is later.
Legislative and Regulatory Ramifications
The Paperwork Burden Reduction Act is somewhat of an anomaly these days given its bipartisan support. The bill was introduced in June 2023 by Republican Jason Smith, a member of the House of Representatives from Missouri. After passage by the House and Senate, it was signed into law by then-President Joe Biden on Dec. 23, 2024.
The new notice marks the first effort by the IRS under the Trump administration to implement aspects of a Biden-era law. The notice and any future documents that mobilize parts of the Paperwork Burden Reduction Act may provide early signals about how the new administration will address/implement other laws.
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