Minimum Essential Coverage Reporting

A look ahead to 2016 requirements

 

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Health Net, like all health plan companies, is required to report Minimum Essential Coverage (MEC) data to the IRS for individuals, including covered dependents, beginning in 2016. As part of this requirement, we have to collect tax identification numbers (TIN) or Social Security numbers (SSN) for your employees if we don’t have them.

 

 

Minimum Essential Coverage (MEC) reporting is a requirement under Section 6055 of the Affordable Care Act. Beginning in 2016, Health Net is required to file:

  • Form 1094-B: the transmittal to the IRS – electronically filed by March 31, 2016, for 2015 and annually thereafter.
  • Form 1095-B: the return – filed along with the transmittal; copy to the individual consumer by January 31 of the year following the coverage year.

 

Both forms are filed for these plan types:

  • Individual & Family Plan, off-exchange
  • Small Business Group, fully insured, off-exchange and SHOP
  • Large group, fully insured

Reporting is not required for government programs including state health plans, Medicare, and Medicaid (Medi-Cal in California).

 

SSN/TIN Collection

The IRS forms require the name and Social Security number (SSN) or a tax identification number (TIN) for each covered individual. The months for which that individual was enrolled for at least one day of coverage and entitled to receive benefits also will be reported.

Health Net is required to make three attempts to collect SSNs/TINs for covered members in order to provide complete reporting to the IRS. Our first attempt is at the time of enrollment, followed by two annual solicitations. We will begin these attempts this year. Please encourage your employees to include TIN/SSNs for themselves and their covered dependents if they receive a request from Health Net.

Reassure them that it is completely safe to give Health Net this information. It’s also to their benefit. Without the SSN/TIN, the IRS will not be able to match coverage reported on your client’s IRS Form 1040 with the coverage information Health Net will report on the Form 1095-B. The inability to match could result in a tax penalty related to the ACA individual responsibility mandate.

 

Filing Requirements At-a-Glance

In addition to the forms that health plans are required to file, the Marketplaces and certain employer groups also have form-filing requirements. The chart below outlines who sends what form.

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Additional Forms and Information
IRS Form 1095-A – Health Insurance Marketplace Statement
IRS Form 1094-C – Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
IRS Form 1095-C – Employer-Provided Health Insurance Offer and Coverage Insurance
IRS Form 1094-B – Transmittal of Health Coverage Information Returns
IRS Form 1095-B – Health Coverage
IRS FAQ – ESR section 6056 reporting

This information is for general purposes only and is not legal or tax advice. For more detailed information about IRS filings, tax or legal implications, please contact your professional tax advisor or legal counselor.

 

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Stacy Madden