Health Care Reform Update
Minimum Essential Coverage (Section 6055) and Large Employer (Section 6056) reporting are required by the Affordable Care Act to help the Internal Revenue Service (IRS) administer compliance with the individual and employer mandates, respectively.
As a self-funded plan sponsor, your organization is responsible to complete Minimum Essential Coverage (MEC) reporting for those individuals covered under your self-funded health plan during the 2015 calendar year. All employees named in this report must also be provided with a copy of the IRS form or an alternative statement that includes the identical data.
In addition, if you have 50 or more full-time and/or full-time equivalent employees, you must report annually, as part of the Large Employer reporting requirement, on the medical coverage you offer to your full-time employees and their dependent children. All employees named in this report must also be provided with a copy of the IRS form or an alternative statement that includes the identical data.
When is the reporting due?
The statements to individuals for both Minimum Essential Coverage and Large Employer reporting (if applicable) are due by January 31, 2016 for 2015 calendar year coverage. The MEC and Large Employer reporting must be submitted to the IRS byMarch 31, 2016 if filing electronically or by February 28, 2016 and February 29, 2016, respectively, if filing by paper. Electronic transmittal is required if filing at least 250 forms.
MEC Reporting – Outreach for missing SSNs
To comply with the MEC Reporting requirement, your organization is required, to make Health Care Reform Update INFORMED ON REF RM KEEPING YOU UP-TO-DATE ON THE PPACA “reasonable attempts” to obtain Social Security Numbers (SSNs) and Tax Identification Numbers (TINs) from those individuals whose data you don’t have on file for identification purposes for the IRS.
“Reasonable attempts” are defined as three attempts to obtain the SSN/TIN before any annual filing. Enrollment can satisfy the first attempt as long as there is a space to provide the SSN/TIN. The second and third attempts are generally required byDecember 31 of that same year and December 31 of the following year. If SSNs/TINs are still not received after making three attempts, the date of birth may be used to help the IRS confirm the identity of those individuals.
A small employer (less than 50 full-time equivalent employees) will use Forms 1094-B and 1095-B.
An Applicable Large Employer (50 or more full-time equivalent employees) will use Forms 1094-C and 1095-C.
Where do I go from here?
Because these are IRS forms, the insurance company cannot provide guidance or information pertaining to the completion or filing of these forms. As your broker, we are limited as well, but can offer some assistance.
However, you should consult with your CPA as soon as you can to be sure you are familiar with the requirements and the data necessary to complete the forms.
***Please click here for more information***
The Trade Preferences Extension Act of 2015 (“Act”), signed into law by President Obama on June 29, significantly increases potential penalties for insurers and employers that fail to comply with the new Affordable Care Act (ACA) Minimum Essential Coverage (MEC) and Large Employer reporting requirements first due in 2016.
***Click here to view penalties for failure to complete the forms mentioned above.***
Scott Bolitho and Jim Harris
Glenwood Insurance Agency