ACA Distribution Just Changed: What Employers Need to Know 

The Paperwork Burden Reduction Act (PBRA), signed December 23, 2024, changes how employers provide ACA Form 1095-C to employees. With this, employers are no longer federally required to automatically mail forms to employees. Instead, they must make it easy for employees to request a copy — and clearly explain how to do that.

Below is a quick, practical guide on what’s changed, what hasn’t, and how to choose a low-risk, low-effort path forward.

Under the new rules, employers do not have to automatically mail 1095-Cs to all employees. However, they now have a notice obligation and specific requirements for how to fulfill it. Specifically, PBRA requires employers to post a clear, easy-to-find notice on their website explaining how an individual can request a copy of Form 1095-C.  The notice must: 

• Be posted by the IRS filing deadline and remain available through October 15 of the following year.  

• Include an email address, a physical mailing address and a phone number for request-related questions  

• Result in timeline fulfillment when a request is received 

Together, these changes heighten the importance of clear communication, reliable tracking, and strong documentation. If you choose to manage distribution based on employee preferences, you’ll need confidence in how those requests are collected, fulfilled, and logged. 

Despite the federal changes, state mandates still apply — some states with individual mandates, including California, New Jersey, Rhode Island, and Washington, D.C., still require paper distribution for certain employees. Filing rules and deadlines remain in place, and your responsibility to submit accurate ACA information to the IRS hasn’t changed. Penalties are still a risk, so accuracy, timeliness, and a well-documented process are essential.

PBRA gives you more flexibility, but how you operationalize it depends on your internal processes, appetite for change management, and team bandwidth. Below are two clear paths that will keep you compliant under the new rules:  

Option 1:  Print forms for only a subset of employees 

This approach requires collecting, tracking, and fulfilling based on each employee’s preference. Ideally, this is done within your benefits administration platform so that everything flows through a single system – reducing manual steps and with that a higher risk of errors or delays. 

Key Considerations:

• Set the default: Choose whether employees will automatically be opted in to receive paper forms (with the ability to opt out) or opted out (with the ability to opt in).  

• Revisit your fulfillment setup: Preference collection and fulfillment work best when managed together. Using separate vendors may introduce manual steps and increase the risk of errors or delays. 

• Plan for special populations: Since terminated employees usually can’t access your benefits administration platform, it can be challenging to make instructions for requesting 1095 forms easily accessible for them. Automatically mailing a printed form for terminated employees is often the simplest way to stay compliant. 

• Stay compliant with state rules: Ensure that employees in states with mailing requirements — like California and New Jersey — continue to receive a paper form to meet state-specific mandates. 

Option 2: Continue to send printed forms to every employee 

If you prefer not to collect, manage and track employee preferences, you can continue to send printed forms to every employee, just as you’ve done in the past. The downside here is that it limits personalization, meaning employees don’t get to decide whether they want to receive a paper form.  However, it’s straightforward and fully compliant with federal and state requirements. 

As you evaluate your path forward, the key will be aligning your approach with your operational capacity — balancing simplicity, compliance, and employee experience. There’s no one-size-fits-all answer, but both options give you a way to stay compliant, minimize risk, and maintain confidence in your ACA processes. 

We’ve enhanced our ACA capabilities to make either path — preference-driven or mail-to-all — easy, compliant, and efficient, with configurable fulfillment workflows so you can choose the best approach for your business. PlanSource offers: 

• Built-in tools to capture employee preferences and manage requests end to end, allowing you to collect, track, and document in one place.  

• Support for fulfillment based on each employee’s choice, helping you avoid manual tracking while ensuring accurate, on-time delivery. 

• Robust reporting and an audit trail that provides clear visibility into requests, status, and outcomes to support compliance.  

This change is an opportunity to modernize your ACA fulfillment without increasing risk. Whether you keep things simple by mailing-to-all or implement a preference-driven approach, the key is clear communication, smart configuration, and reliable follow-through.  

Start by talking with your PlanSource representative to determine the option that best fits your organization. If you choose a preference-driven strategy, ask about our PBRA Employee Communication Package to jumpstart employee notices. If you prefer a mail-to-all approach, we’ll lock your configuration and finalize your timeline.

1. Do we have to collect preferences? No. Preference collection is optional. You can continue mailing 1095 forms to everyone if that’s simpler for your organization.
2. Do employees still have a right to a paper form? Yes. You must provide clear instructions on your website for how they can request a copy of their 1095-C form. These instructions must include an email address, a physical address to which a request may be sent, and a telephone number that individuals may use to contact you with any questions. 
3. Are we fully done with mailing? Not necessarily. States with individual mandates—California, New Jersey, Rhode Island, and Washington, D.C.— still require traditional paper distribution for certain employees. 

This article is for informational purposes only and is not legal advice. For guidance specific to your organization, consult your legal counsel or tax advisor.