Minimum Essential Coverage Reporting

Health plan companies, like Health Net, are required to report Minimum Essential Coverage (MEC) data to the IRS for individuals, including covered dependents, beginning in 2016. This requirement is Section 6055 of the Affordable Care Act.

There are two forms 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 is sent to the individual consumer by January 31 of the year following the coverage year.
- Attention: IRS Notice 2016-4, released December 28, 2015, provides additional time for Health Plans to comply with Minimum Essential Coverage filing requirements for tax year 2015. Health Plans must provide Form 1095B to individuals by March 31, 2016 and file the 1094B with the IRS by June 30, 2016.

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).

Reporting details

General

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 plans are required to make three attempts to collect SSNs/TINs for covered members in order to provide complete reporting to the IRS.

Health Net specifics

Health Net will solicit SSN/TIN numbers at time of enrollment, followed by two annual solicitations for any member for whom we do not have a number. We will begin these attempts in 2015.

Please encourage your clients – employer groups and individuals alike – to provide Health Net with SSNs/TINs for themselves and any covered dependents.

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.

Annual statements to consumers

Health plans must send Form 1095-B statements to responsible individuals by January 31 of each year, starting in 2016 for the 2015 calendar year. Consumers can use the statement as supporting documentation for tax purposes.

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.

The chart below summarizes the responsibility for entities that provides Minimum Essential Coverage and are subject to Employer Shared Responsibility.

**Responsibility for entities that provider Minimum Essential Coverage**
Plan Type	Minimum Essential Coverage Reporting (Section 6055)	Employer Shared Responsibility Reporting (Section 6056)
Individual (marketplace plan)	Form 1095-A Sent by the marketplace	N/A
Individual (non‑marketplace)	Forms 1094-B and 1095-B Filed and sent by the health plan	N/A
Small Group fully insured plan (SHOP and non‑marketplace)	Forms 1094-B and 1095-B Filed and sent by the health plan	N/A
Small Group self-insured plan (non-ALE)	Forms 1094-B and 1095-B Employer's responsibility to file and send statements to employees/former employees	N/A
ALE fully insured plan	Forms 1094-B and 1095-B Filed and sent by the health plan	Forms 1094-C and 1095-C (sections I and II only) Employer's responsibility to file and send statements to employees
ALE self-insured plan	Forms 1094-C and 1095-C (all sections) Employer's responsibility to file and send statements to employees Self-insured large group plans meet reporting requirements of both section 6055 and 6056 by filing Forms 1094-C and 1095-C	Forms 1094-C and 1095-C (all sections) Employer's responsibility to file and send statements to employees Self-insured large group plans meet reporting requirements of both section 6055 and 6056 by filing Forms 1094-C and 1095-C

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

More details about the ACA employer shared responsibility.

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