MLR

New reporting requirements for employer-provided healthcare benefits

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Employers should already be preparing to comply with next year’s Affordable Care Act reporting requirements regarding their employee healthcare benefits.

Self-insuring employers and employers with 50 or more full-time employees are required under the Affordable Care Act to file information with the IRS about health insurance coverage provided – or not provided – to their employees.

The required reporting with respect to calendar year 2015 begins with providing an information return to the IRS by Feb. 28, 2016, or March 31, 2016, if reporting electronically. But employers should have already begun pulling together the 2015 health coverage information for each month.

Self-insuring employers – Code Section 6055

Self-insuring employers must file an information return with the IRS using Form 1095-B, Health Coverage, and Form 1094-B, Transmittal of Health Coverage Information Returns, each year, providing information about minimum essential coverage for each individual receiving the coverage. The forms must be filed by Feb. 28, or March 31 if reporting electronically.

Minimum coverage is defined as a healthcare plan designed to pay at least 60 percent of the total cost of medical services for a standard population. Most employer-sponsored health coverage qualifies as “minimum essential coverage.” However, specialized coverage, such as vision and dental care, workers’ compensation, disability policies and coverage for only specific health issues, does not qualify.

The required information return must contain the following:

  • Name, address and taxpayer identification number of the primary insured, as well as the name and taxpayer identification number of any family members of the primary insured who are also covered under this policy.
  • Dates during which individuals were covered under minimum essential coverage during the year.
  • Whether the health insurance is a qualified health plan in the small group market offered through an exchange. In a situation where employers are providing minimum essential health insurance coverage during the year, they must provide information regarding whether the coverage is a qualified health plan offered through a healthcare exchange and how much the amount of the advance payment is, if any.
  • Any additional information the IRS requires.

If the minimum essential coverage is provided by the employer through a traditional group health plan, a return is still required to be filed by the deadline.

The return must contain the following information:

  • Name, address, and employer identification number of the employer maintaining the plan
  • Portion of the premium, if any, required to be paid by the employer
  • Any other information the IRS requires

Employers providing health insurance coverage are also required to furnish related information about the coverage to each individual. For calendar year 2015, the information is due to individuals by Jan. 31, 2016.

These statements must provide the following information:

  • The name and address of the employer maintaining the plan, and a contact name and phone number that the employees can access if they have any questions
  • The information required to be reported on the return with respect to such individual

Large employers – Code Section 6056

Large employers with 50 full-time or full-time equivalent employees must file Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, and Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Return, with the IRS by Feb. 28, 2016, or March 31 if reporting electronically. This information return reports the terms and conditions of the healthcare coverage they provided to their employees for the calendar year.

The employers must also provide related information to their employees by Jan. 31, 2016.

The information return must include the following:

  • Employer’s name and identification number
  • Date the return is filed
  • Certification of whether the employer offers full-time employees and their dependents the opportunity to enroll in minimum essential coverage under an eligible employer-sponsored plan
  • Number of full-time employees for each month of the calendar year
  • Name, address and taxpayer identification number of each full-time employee employed by the employer during the calendar year and any months during which the employee and any dependents were covered under the eligible employer-sponsored plan during the calendar year
  • Any other information the IRS requires

Large employers that offer employees the opportunity to enroll in minimum essential coverage are required to report:

  • Duration of any waiting period for the coverage
  • Months during the calendar year when coverage was available
  • Monthly premium for the option that cost the lowest amount in each enrollment category
  • Employer’s share of the total allowed costs of benefits under the plan