What to Do If You Missed Filing ACA Forms for a Prior Year – and How 1099FIRE Can Help
Erich Ruth
Failing to file Affordable Care Act (ACA) information returns—Forms 1095-B, 1095-C, and transmittals 1094-B/C—for a prior year can be stressful. The IRS requires applicable large employers (ALEs), insurance carriers, and certain other entities to report health coverage information annually. If you’ve missed a filing deadline for a past year, you still have options—but time matters.
1. Act Quickly to Limit Penalties
The IRS can impose penalties for both failing to file with the IRS and failing to furnish forms to employees. Penalties increase the longer you wait. For 2024 filings, for example:
- $60 per form if filed within 30 days after the due date
- $120 per form if filed more than 30 days late but before August 1
- $310 per form if filed after August 1 or not at all
- Maximum annual penalties can reach millions for large filers
Even if you missed the original deadline by years, filing now can stop further penalty escalation.
2. Prepare and Submit Late or Corrected Forms
If you missed a filing year, you must:
- Prepare Forms 1095-B/C for each covered individual or employee
- Prepare the corresponding transmittal (Form 1094-B/C)
- E-file through the IRS AIR (Affordable Care Act Information Returns) system
- Provide copies to employees/covered individuals, even if late
3. Consider Penalty Abatement
You may be able to request a penalty abatement if:
- This is your first time missing the ACA filing deadline
- You can show “reasonable cause” (e.g., natural disaster, major system failure)
- You acted promptly once you realized the omission
Supporting documentation strengthens your case.
4. How 1099FIRE Can Help
1099FIRE specializes in ACA form preparation, correction, and late filing services. Here’s how we assist:
- Data Import & Formatting – We can take your existing employee or coverage data in Excel/CSV format and convert it into IRS-compliant XML files for the AIR system.
- E-File Support – We transmit directly through the IRS AIR platform, ensuring your late filings are properly acknowledged.
- Correction Handling – If you previously filed with errors, we handle ACA correction submissions so you remain compliant.
- State Reporting – For jurisdictions with their own ACA mandates (California, New Jersey, Rhode Island, D.C., Massachusetts), we also prepare and transmit to state agencies.
- Penalty Mitigation – We can advise on how to accompany your late filings with a penalty abatement request to reduce or eliminate fines.
Bottom Line
If you’ve missed ACA form filing for a prior year, don’t wait—the sooner you file, the better your chances of reducing penalties. Partnering with 1099FIRE gives you the expertise, technology, and support to quickly prepare, correct, and transmit your ACA forms to both the IRS and employees, even for past years.