This post is part of a series leading to our free webinar on reporting that will take place on Tuesday, June 2 at 10:00 a.m. You can register for the webinar here.
The Affordable Care Act created new reporting requirements in the Internal Revenue Code Section 6055 which requires health insurance companies, sponsors of self-insured plans, and other organizations that provide minimum essential coverage to file information with the IRS about the health coverage they offer. In this blog post, AUI will help answer some questions about what information must be reported to comply with Section 6055.
The following entities are responsible for completing their own Section 6055 reporting:
- Large Employers with a self-insured group health plan
- Small Employers with a self-insured Group Plan
- Multi-Employer Plans
Large employers with a fully-insured plan will have 6055 reporting completed by the carrier, but the employer will have to complete Section 6056.
The Section 6055 reporting is done by using Forms 1094-B and 1095-B. Each reporting entity will file:
- A single transmittal form (1094-B) for all of the returns filed for a given calendar year
- A separate statement (For 1095-B) for each responsible individual provided with minimum essential coverage (MEC) during the year
A self-insured plan sponsor who is also subject to the ACA’s employer share responsibility rules must also report under Code Section 6056 as an applicable large employer. Entities that report under both Sections will file using a combined reporting method, suing Form 1094-C and Form 1095-C. These forms allows the sponsor of a self-insured plan to combine all of the reporting requirements that satisfy both 6055 and 6056 reporting.
Form 1094-B: Required Information
Each reporting entity is required to report information about the health coverage it provided to any individual during the calendar year. One Form 1094-B transmittal must be filed with any Forms 1095-B. The following information must be included on Form 1094-B on the lines indicated by all reporting entities:
- Line 1: Filer’s name
- Line 2: Filer’s non-digit EIN, including the dash
- Line 3: Name of the filer’s contact person who is responsible for answering questions
- Line 4: Telephone number of teh filer’s contact person
- Lines 5-8: Filer’s complete address (including room or suite number if applicable)
- Line 9: Total number of Forms 1095-B submitted with this Form 1094-B transmittal
Form 1095-B: Required Information
One Form 1095-B must be filed for each responsible individual. The “responsible individual” is the person who enrolls one or more individuals, which may include the responsible individual, in minimum essential coverage. This responsible individual may be an employee, the primary insured, a former employee, uniformed services sponsor, parent, or other related person named on the coverage application.
The following information must be included on Form 1095-B on the lines indicated.
- Part I // Line 1: Responsible individual’s name
- Part I // Line 2: Responsible individual’s nine-digit SSN, including dashes (if individual does not have an SSN, use other TIN)
- Part I // Line 3: Responsible individual’s date of birth (MM/DD/YYY), only if line 2 is blank
- Part I // Line 4-7: Responsible Individual’s complete address (including apartment number if applicable)
- Part I // Line 8: Letter identifying the origin of the policy or coverage (A. Small Business Health Options Program (SHOP), B. Employer-sponsored coverage, C. Government-sponsored coverage, D. Individual market insurance, E. Multi employer plan, F. Miscellaneous minimum essential coverage
- Part I // Line 9: Small Business Health Options Program (SHOP) Marketplace identifier, if applicable (leave blank for 2014)
- Part II // Line 10-15: Name, EIN and complete mailing address for the employer sponsoring the coverage (to be completed by issuers or carriers of insured group health plans ONLY)
- Part III // Line 16-22: Name, EIN and complete mailing address for the coverage provider, and telephone number for the coverage provider’s contact person
- Part IV // Column (a) 23-28: Name of each individual enrolled in the MEC
- Part IV // Column (b) 23-28: Nine-digit SSN for each covered individual, including the dashes (or other TIN, if the covered individual does not have an SSN)
- Part IV // Column (c) 23-28: Date of Birth (MM/DD/YYYY) for the covered individual, only if column (b) is blank
- Part IV // Column (d) 23-28: Whether the individual was covered for at least one day per month for all 12 months of the calendar year (check this box if yes)
- Part IV // Column (e) 23-28: If the individual was not covered for all 12 months of the calendar year, the months in which the individual was covered for at least one day of the month (check applicable boxes)
Reporting Social Security Numbers
Reporting entities are required to report the Social Security number or other Taxpayer Identification Number for each covered individual. If a reporting entity is unable to obtain an SSN after making a reasonable effort to do to, the covered individual’s date of birth (MM/DD/YYYY) may be entered lieu of an SSN.
In order to show that a reasonable effort to obtain an SSN, the reporting entity must make:
- An initial solicitation at the time the relationship with the payee is established
- If the reporting entity does not receive the TIN, the first annual solicitation is generally required by December 31 of the year in which the relationship with the payee begins
- If the TIN is not provided, a second solicitation is required by December 31 of the following year
If a TIN is still not provided, the reporting entity need not continue to solicit a TIN. If the responsible individual is not enrolled in the coverage, providers may, but are not required to, report the TIN of the responsible individual.
Concerned about identity theft on documents? Fortunately, employee statements may truncate the TIN or SSN of a covered individual on any statements furnished to individuals, by showing only the last four digits of the TIN or SSN and replacing the first five digits with asterisks or Xs. Truncation is not allowed on forms filed with the IRS. In addition, an Employer Identification Number may not be truncated on the forms filed with the IRS.
If you have additional questions about Section 6055 reporting, please feel free to e-mail one of our insurance experts by clicking here. At AUI we work hard to keep our clients ahead of healthcare regulations.
Disclaimer: The intent of this analysis is to provide general information regarding the provisions of current healthcare reform legislation and regulation. It does not necessarily fully address all your organization’s specific issues. It should not be construed as, nor is it intended to provide, legal advice. Your organization’s general counsel or an attorney who specializes in this practice area should address questions regarding specific issues.