On December 23, 2024, the Paperwork Burden Reduction Act (PBRA) was signed into law. This new law aims to streamline ACA reporting requirements and reduce administrative overhead for businesses and individuals.
While this legislation is set to simplify some paperwork requirements and lower associated costs, a lack of specific guidelines presents potential challenges that employers must consider moving forward, especially for the 2024 reporting year.

Previously, employers were mandated to furnish the 1095-C ACA Form to all employees, detailing their health coverage. Under the PBRA, beginning with the 2024 reporting year, these paper forms are only required only upon an employee’s request.
It’s important to note that certain states with individual health insurance mandates, including California, Massachusetts, New Jersey, Rhode Island (and Washington D.C.) may still require employers to provide the 1095-C Form to employees.
Additionally, to take advantage of this new law, employers must inform employees of this option through a clear and accessible notice and must supply the requested form by January 31 or 30 days after the request — whichever of the two is later.
However, it is not clear when employers must provide the notice, how often the notice must be provided, and whether the notice needs to be provided as a hard copy, electronically, or both. Any employer that creates and distributes its own notice risks that the notice might not meet future requirements. If the IRS decides the notice is insufficient, the employer could face penalties.

Given the ongoing requirement to provide paper forms in certain states and the lack of specific guidelines on how to comply with the PBRA, the safest course of action for employers is to continue providing paper forms for the 2024 reporting year. This approach ensures compliance and minimizes administrative burden until more specific requirements are released.
This approach also allows employers to collaborate with their ACA compliance partner to better understand their options for notifying employees about how to request a 1095 form, ensuring full compliance with the PBRA.

At PlanSource, we are committed to helping employers stay informed and compliant with the latest regulatory requirements. We offer comprehensive ACA compliance and fulfillment services to help employers avoid penalties, reduce administrative burden, and receive expert guidance.