QUESTION: Our company is an applicable large employer (ALE) and would like to distribute Form 1095-C electronically to employees. If an employee previously consented to receiving Form W-2 electronically, does that consent also apply to Form 1095-C?
ANSWER: Unless the employee’s consent specifically identifies Form 1095-C, it will not serve as valid consent to receive Form 1095-C electronically. As background, Code § 6056 requires an ALE to provide information to the IRS and full-time employees about the health coverage offered by the ALE. Form 1095-C provides information about the coverage offered to each full-time employee, and it is the employee statement that must be filed with the IRS and furnished to employees upon request when certain requirements are met.
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