Last Updated on January 8, 2025

Small businesses with fewer than 50 full-time equivalent (FTE) employees face critical Affordable Care Act (ACA) filing requirements. Compliance is essential to avoid penalties and ensure smooth operations. This guide explores the ACA filing requirements for small groups, the role of Form 1095-B and the limitations of relying solely on carriers for filing. Finally, we highlight how MyHRConcierge can help ease your business’s ACA filing. 

ACA Filing Basics for Small Groups 

The ACA mandates that applicable large employers (ALEs) with 50 or more FTEs file and furnish certain forms annually. However, small groups (those with fewer than 50 FTEs) are not exempt from all ACA obligations, especially when they offer self funded health plans, such as level-funded arrangements. 

Small groups sponsoring self-insured or level-funded health plans must file 1094-B and 1095-B forms to report health coverage details to the IRS and employees.  

The Unique Requirements for Level-Funded Plans 

Level-funded health plans—a hybrid between fully insured and self-insured plans—have grown in popularity among small businesses. They offer cost predictability, potential refunds, and flexibility, but they also come with added compliance responsibilities. Employers with level-funded plans are considered self-insured for ACA purposes, meaning they must: 

• File Form 1094-B (transmittal form) along with copies of the Form 1095-B to the IRS. 

• Provide Form 1095-B to employees, detailing the months each individual had Minimum Essential Coverage (MEC). 

Failure to meet these requirements can result in penalties, making it crucial to prioritize timely and accurate filing. 

Most Carriers Will Provide Forms, But Not All Will File Forms for You

A common misconception is that health insurance carriers handle all ACA filing responsibilities. While carriers typically generate Form 1095-B for employers offering level-funded plans, most do not electronically file the forms with the IRS. This leaves small employers responsible for submitting the Forms 1094-B and 1095-B to the IRS.  

Historically, the IRS allowed employers with less than 250 forms to mail the forms to the IRS. However, beginning in January 2024 the IRS began requiring any company with 10 or more forms to electronically file them to the IRS.  Therefore, it is important to clarify with your carrier whether they just provide the forms to the employer or if they are also e-filing them to the IRS.  

Deadlines to Remember 

For 2024, the key ACA filing deadlines are: 

• March 3, 2024: Deadline to furnish Form 1095-B to employees. 

• March 31, 2024: Deadline to file electronically with the IRS. 

Missing these deadlines can lead to costly penalties. Planning ahead is essential for compliance. 

How MyHRConcierge Can Help 

Navigating ACA filing requirements can be daunting for small businesses, especially those unfamiliar with the complexities of level-funded plans. MyHRConcierge offers ACACompli™, a comprehensive Affordable Care Act compliance and administration service for companies of all sizes. Here’s how our white glove service can support you: 

• Preparation and Filing: We handle the preparation and electronic filing of Forms 1094-B and 1095-B, ensuring compliance with IRS regulations. All you have to do is ensure that 1095-B forms provided by your carrier are provided to MyHRConcierge, and we will e-file the forms to the IRS on your behalf. Once completed, you will receive confirmation of the filing. 

• Expert Guidance: Our team provides personalized assistance to address your specific filing needs and ensure accuracy. 

• Deadline Management: We track critical deadlines and manage the filing process to help you avoid penalties. 

Partnering with MyHRConcierge allows small businesses to focus on growth while we take care of your ACA compliance. 

Easing the ACA Filing Burden for Small Groups

As ACA compliance requirements evolve, small groups must stay informed and proactive. Level-funded plans bring valuable benefits but also added responsibilities for ACA filing. Remember, most carriers will not file forms to the IRS on your behalf, leaving you accountable. 

If you’d like to sign up for our year-end reporting services, you can do so here. 

Let MyHRConcierge ease the burden of ACA filing for your small business. To learn more about our services and ensure a stress-free filing experience this year, contact us today at ccooley@myhrconcierge.com, 855-538-6947 ext 108. Or, schedule a free consultation below: