The Affordable Care Act (ACA) made widespread reforms to health plan coverage when it was enacted in 2010. Since then, changes have been made to various ACA requirements for employer-sponsored health coverage. These changes include annual cost-of-living increases to certain ACA dollar limits, adjustments to ACA reporting requirements and updates to preventive care coverage guidelines.
Changes to some ACA requirements will take effect in 2025 for employers sponsoring group health plans. For example, the affordability percentage under the ACA’s employer mandate rules for applicable large employers (ALEs) will increase slightly for plan years beginning in 2025, which may provide ALEs with more flexibility when setting their employee contribution rates.
To prepare for 2025, employers can use this checklist to review these ACA requirements and develop a compliance strategy. Employers should ensure that their health plan documents, including the summary of benefits and coverage (SBC), are updated to reflect any new plan limits. Employers should also ensure that up-to-date information is communicated to employees at open enrollment time.
Plan Design Changes
The following plan design requirements have changed for 2025:
- Limits on cost sharing for essential health benefits;
- Coverage affordability percentage under the employer mandate rules; and
- Dollar amounts for calculating penalties under the employer mandate rules.
Reporting Deadlines
The following deadlines apply for reporting under Sections 6055 and 6056:
- March 3, 2025: Individual statements for 2024 must be furnished by this date. An alternative method of furnishing Form 1095-B is available; and
- March 31, 2025: Electronic IRS returns for 2024 must be filed by this date.
LINKS AND RESOURCES
IRS Rev. Proc. 2024-35 indexed the ACA’s affordability percentage for plan years beginning in 2025.
IRS Rev. Proc. 2024-14 modified the penalty amounts under the ACA’s employer mandate for 2025.
CMS guidance established the cost-sharing limits for 2025 plan years.