This month’s article highlights ACA Reporting Requirements for Forms 1094 and 1095, Employers and Paternity Leave, and state requirements for Short-Term Disability Insurance.

ACA Reporting Requirements for Forms 1094 and 1095

ACA reporting involves the submission of Forms 1095 and 1094 by employers to the IRS each year. These forms are crucial for ensuring compliance with the Affordable Care Act (ACA).

Form 1095 provides details about the health insurance coverage offered to employees, while Form 1094 serves as a summary transmittal form.

This reporting is important because it helps the IRS verify that employers are meeting their obligations under the ACA, such as providing affordable health coverage to their employees.

Accurate ACA reporting also helps employees understand their health insurance status and eligibility for premium tax credits.

Key Upcoming ACA Reporting

Requirements for paper filing, employee statements and electronic filing include:

1. Required Paper Filing: The IRS requires Applicable Large Employers (ALEs) to send ACA reports to ensure compliance with ACA regulations. ALEs are employers with 50 or more full-time or full-time equivalent employees. Employers with 50 or more full-time employees (including full-time equivalent employees) must file Forms 1094-C and 1095-C with the IRS. If they choose to file by paper, the deadline is February 28, 2026.
2. Required Employee Statements: Employers are required to furnish Form 1095-C to each fulltime employee, detailing the health insurance coverage offered. In California, these statements must be provided by January 31. In Colorado, Florida, Minnesota, Oklahoma, and Texas, the deadline is March 3, 2026. The forms can be delivered by mail or electronically, with the employee’s consent.
3. Required Electronic Filing: If a broker’s client is filing 10 or more forms, they are required to file electronically through the ACA Information Returns (AIR) system. The deadline for electronic filing is March 31, 2026.

Employers and Paternity Leave

What can an employer do about paternity leave coverage? Outside of the Family and Medical Leave Act (FMLA), paternity leave coverage is available through state Paid Family and Medical Leave (PFML) programs and employer-sponsored paid parental leave policies.

States With Paid Family Leave Programs

As of 2025, 13 states and Washington, D.C., have mandatory PFML programs, and several others have voluntary or upcoming programs. These programs provide paid time off for bonding with a new child, which applies equally to fathers.

Employer-Sponsored Paid Parental Leave

• Only 23% of U.S. workers have access to paid parental leave through their employer.
• Policies vary widely: Some employers offer 2 – 12weeks fully paid, while others provide partial pay or flexible bonding time.
• Federal employees have a separate Paid Parental Leave program offering 12 weeks of paid leave.

Key Considerations for Employers

• Location is critical: If the business operates instates with PFML, employees already have access to paid paternity leave.
• Employer discretion: In states without PFML, the company can choose to add voluntary paid parental leave to its benefits package.
• Coordination with FMLA: PFML usually runsconcurrently with FMLA, meaning employees don’tget double time but do get wage replacement.
• Competitive advantage: Offering paid paternityleave can improve retention, morale and workplace equity.

What States Require Short-Term Disability Insurance?

Five states (plus Puerto Rico) require employers to provide state-mandated short-term disability insurance. They are California, Hawaii, New Jersey, New York, Rhode Island, and Puerto Rico.

State Disability Insurance Contacts & Resources

These agencies provide:

• Employer compliance guides
• Forms for private plan approval
• Contribution rate updates

Key Notes for Employers

• Private STD/LTD plans (like those from Principal or Hartford) do not automatically satisfy state mandates, unless approved by the state as a substitute.
• New York requires employers to provide coverage for non-work-related disabilities for employees residing in the state, even if the company is headquartered elsewhere.
• California, where your group is located, also has a mandatory SDI program funded by employee payroll deductions.
• Multi-state employers must comply with each state’s disability insurance laws for employees residing in those states.

Brought to you by Black, Gould & Associates Inc

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