Don’t Forget: ACA Reporting Is Required for ICHRA Plans
When it comes to Individual Coverage Health Reimbursement Arrangements (ICHRAs), flexibility and choice are what make them so appealing. But with that flexibility comes responsibility, especially when it comes to Affordable Care Act (ACA) reporting.
If your organization offers an ICHRA, you are legally required to complete ACA reporting, no matter your group size. It’s one of the most commonly overlooked compliance requirements, but skipping it can lead to costly penalties and unnecessary stress at year-end.
Let’s walk through what you need to know, when to file, and how to make sure your reporting goes smoothly.
Why ACA Reporting Applies to ICHRA Plans
ICHRAs are considered self-funded health plans under IRS rules. That means employers, whether large or small, must comply with ACA information reporting requirements.
This involves filing two key forms:
- Form 1095-B or 1095-C: Provided to each employee who was offered coverage. This form outlines the type of coverage offered, to whom, and for which months.
- Form 1094-C: Filed with the IRS to summarize your organization’s coverage details for the year.
These forms ensure the IRS can verify that your organization met ACA employer mandate requirements and that employees had access to compliant health coverage.
Key Deadlines to Mark on Your Calendar
March 2, 2026 – Provide Form 1095-B/C to employees.
March 31, 2026 – File Form 1094-C with the IRS (for electronic filers).
These dates may seem far off, but the preparation process takes time, especially if this is your first year managing ACA reporting for an ICHRA.
Why Early Prep Matters
Year-end is already busy with open enrollment, payroll updates, and compliance renewals. Waiting until January to start ACA reporting adds unnecessary stress and increases the risk of errors.
By starting your ACA prep in December, you’ll have time to:
- Verify your employee eligibility and coverage data.
- Review contribution amounts and affordability calculations.
- Ensure your employee notices are accurate and ready for distribution.
- Identify and correct any inconsistencies before forms are sent to employees or filed with the IRS.
The earlier you start, the smoother the process will be, and the better your compliance position heading into 2026.
What Happens If You Miss the Deadline?
The IRS takes ACA reporting seriously. Employers that fail to file or furnish accurate forms can face penalties of up to $310 per form, which can quickly add up.
Beyond the fines, late or incorrect reporting can create confusion for employees, delay tax filings, and trigger additional IRS correspondence, all of which can be avoided with proper preparation.
How Ameriflex Can Help
At Ameriflex, we make ACA reporting for ICHRA plans simple. Our compliance team helps employers collect, verify, and file all required documentation, accurately and on time.
Whether you’re new to ICHRA or simply need a smoother reporting experience, we’ll walk you through each step so nothing slips through the cracks.
It’s not too late to get started, but the earlier you begin, the easier it gets.
Let’s take care of your ACA reporting now, so you can focus on your people, not paperwork.