Prior to TY23 [reporting in 2024], employers belonging to a MULTIPLE EMPLOYER WELFARE ARRANGEMENT [MEWA] could submit ACA forms to the IRS via paper. The IRS now requires electronic filing by all employers, even those with with fewer than 10 employees.

These smaller, non-ALE employers belonging to MEWAs are unlikely to have gone through the complex certification required to obtain an IRS Transmitter Control Code [TCC] for e-filing via the IRSAIR system.

BENEFITSCAPE uses its TCC to provide FORM 1095 e-filing for these employers to the IRS.

ACA Reporting Requirements for MEWAs can be downloaded here.

The TY26 ACA FORM 1095 Deadlines are as follows:

Distribution to employees: March 2, 2027 [30 days after Jan 31]

E-filing to the IRS: March 31, 2027 

Paper filing: Feb 28, 2027 

For help on any aspect of MEWA ACA Compliance & Reporting, please contact BENEFITSCAPE.