IRS Issues Guidance on Alternative Health Coverage Reporting Method
Published February 24, 2025
The Internal Revenue Service (IRS) issued Notice 2025-15, providing guidance regarding the alternative manner of furnishing certain health insurance coverage statements to individuals under Internal Revenue Code (IRC) sections 6055(c)(3) and 6056(c)(3). This method allows insurers and applicable large employers (ALEs) to comply with their reporting obligations by posting an online notice rather than automatically furnishing statements to individuals.
Under IRC 6055, entities providing minimum essential coverage must report coverage details to IRS and furnish statements to responsible individuals. IRC 6056 requires ALEs, generally those with 50 or more full-time employees, to report health insurance information for those employees. The Paperwork Burden Reduction Act amended these sections to introduce an alternative furnishing method, effective for statements related to returns for calendar years after 2023.
Instead of automatically providing statements, reporting entities may post a clear and conspicuous notice on their websites, informing individuals that they may request a copy of their statement. The notice must be posted by the original furnishing deadline, including any automatic 30-day extension, and must remain accessible through October 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 January 31 of the following year, whichever is later.
Under Notice 2025-15:
- For statements related to the 2024 calendar year, the notice must be posted by March 3, 2025.
- Statements may be furnished electronically if permitted under Reg. §1.6055-2 for minimum essential coverage providers and Reg. §301.6056-2 for ALEs.
- The alternative method applies regardless of whether the individual shared responsibility payment under IRC 5000A is zero.
- The method applies to statements required under both IRC 6055 and IRC 6056.
- Reg. §1.6055-1(g)(4)(ii)(B) sets forth the requirements for the alternative manner of furnishing statements under IRC 6055, while the same framework applies to IRC 6056 with relevant terminology adjustments.
- Form 1095-B, used for reporting minimum essential coverage, and Form 1095-C, used by ALEs to report health insurance offers, may be provided under this alternative method.
The notice is effective for statements required by sections 6055 or section 6056 with respect to returns for calendar years after 2023.