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6055 and 6056 Reporting


These reporting requirements began in 2016 for the 2015 calendar year. The 6055 reporting, also known as minimum essential coverage (MEC) reporting, is used to enforce the individual mandate and applies to all entities that provide MEC. The 6056 reporting, also known as applicable large employer (ALE) reporting, is used to enforce the employer mandate and applies to all ALEs with 50 or more full time or full time equivalent employees (FTEs). It is important to note that if a self-funded plan is subject to both reporting requirements, they will complete one IRS form to satisfy both requirements; however, there are some exceptions as noted in the Forms section below.

 

6055

6056

Overview

To enforce the individual mandate

To enforce the employer mandate

To whom does the reporting requirement apply?  

Required of all employer-sponsored health plans, regardless of group size, that provide Minimum Essential Coverage (MEC)

Applicable Large Employers (ALEs) with 50 or more FTEs

When is the reporting due?

The deadline for filing each form is the same and is outlined below:

To individuals by January 31st each year. This requirement to provide a notice to individuals may be satisfied by simply copying the IRS form that must be completed. IRS Publication 5223 covers the requirements for acceptable substitutes of the IRS Forms.

To the IRS by February 28th if filing a paper return or by March 31st if filing electronically.  Filing must be done electronically* if filing 250 or more of any form and is encouraged for those filing less than 250 forms.

​What information is required to be reported?

​Information on ALL MEMBERS that were covered for at least one day during the calendar year.  The following information is required:

  • Employee Information, including employee's name and address
  • The names of any dependents covered under the plan
  • The SSN of each covered individual or Date of Birth of the covered individual (if a SSN is not available)
  • Identification of whether the individuals were covered for at least one day in every month of the calendar year or if they were covered for some but not all months and information indicating the months for which the individuals were covered.
  • The name, address, Tax ID and of the employer if employer sponsored plan

Note:  A Description as to the type of coverage each individual had is not required.

​Information on ALL Full-Time EMPLOYEES (those working 30 or more hours per week or 130 or more hours per month) employed at least one full month during the calendar year. Employers must report even if no health plan is offered.

  • The name, address, and SSN of the employee
  • The status of each employee using codes provided by the IRS
  • Information on the type of coverage offered to the employee using codes provided by the IRS
  • Identification as to whether the type of coverage offered, if any, met minimum value
  • The name, address, Tax ID, and telephone number of the employer

Note: Employers must report whether coverage was offered during the month(s) the employee was a full-time employee and whether it was affordable.  If coverage was not offered for an entire month, employers must explain why (for example, the employee was part time during that month).

 

*IRS Form 8508, Request for Waiver From Filing Information Returns Electronically, has been expanded to include Forms 1095 (B and C series) and Form 1094 C. This form needs to be submitted at least 45 days prior to the filing deadline for which the waiver will apply, if approved.

 

MEC for Purposes of 6055 Requirements

MEC for purposes of this reporting includes government-sponsored programs, eligible employer-sponsored plans including self-funded group health plans, individual market plans, and other coverage the Department of Health and Human Services designates as MEC. It is important to note that coverage provided under a government sponsored program such as Children's Health Insurance Program (CHIP), Medicaid, or Medicare (including Medicare Advantage), provided through health insurance companies will be reported by the government sponsors of those programs.

 

Reporting on Individuals Covered by More than One MEC Plan: If an individual is covered by more than one type of MEC plan provided by the same plan sponsor, the plan sponsor is required to report only one of the types of coverage.

 

• Supplemental coverage that is available on the condition of enrollment in another MEC plan does not need to be reported. (For employer-sponsored coverage, this exception applies only if both types of coverage are under group health plans of the same employer).

 

Electronic Filing

Filers submitting the electronic forms directly (those not using an authorized e-file provider) will need to register online to create a user account through IRS Registration Services. Once registered, they must complete the ACA Information Return Transmitter Control Code (TCC) Application to receive a TCC in the mail prior to electronically filing Affordable Care Act Information Return (AIR) Forms 1094-B, 1094-C, 1095-B and 1095-C. Filers using approved software will only need to perform the communications test. All others will use the test scenarios provided by the IRS. Testing is required for the first year only to ensure that the IRS can receive the electronic returns and that filers can retrieve acknowledgements.

 

The IRS has released two publications with regard to the electronic filing of IRS forms 1094/1095 for 6055/6056 reporting. The first publication, IRS Publication 5164, describes the testing that filers must complete successfully before using the IRS's AIR system, which is used for electronic filing. Please remember that this testing is only required of employers who have chosen to file directly with the IRS and are not using a vendor to file for them. This publication includes test scenarios that filers will use, which are also available on the AATS webpage. This publication also clarifies that the only test required of filers using approved software is the communications test.

 

The second publication, IRS Publication 5165 provides general electronic filing guidance. It clarifies that electronic filings may be rejected at one of two levels: transmission level (for example, the transmission doesn't pass security) or the submission level (based on the submission's contents).

 

The Forms

The following summary chart breaks down each form and why it is required. You can find links to the forms and their instructions at the right under External Links.

 

 

Form Name

Purpose

Initiator

Recipient

1095-B: Health Coverage

Reports information on health coverage, including period of coverage, and for whom coverage was provided– including each dependent

Self-funded employers that provide MEC and employ fewer than 50 full-time employees or full-time employee equivalents  

Applicable Large Employers who are missing a non-employee member's SSN*

Health insurer for insured plans

IRS

Copy of information must be sent to Individual

1094-B: Transmittal of Health Coverage Information Returns

Transmittal form filed with Form 1095-B from the insurer to the IRS

Self-funded employers that provide MEC and employ fewer than 50 full-time employees or full-time employee equivalents

Applicable Large Employers who file even one Form 1095-B must file a corresponding 1094-B transmittal form

Health insurer for insured plans

IRS

1095-C: Employer-Provided Health Insurance Offer and Coverage

Reports information on health coverage offered and information on employees and dependents enrollment in that coverage

Applicable Large Employer Fully Insured or Self Insured

IRS

Copy of information must be sent to Individual

1094-C: Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns

Transmittal form filed with Form 1095-C from the insurer to the IRS

Applicable Large Employer Fully Insured or Self Insured

IRS

 

*In this situation, the non-employee member, the employee under whom the non-employee member is enrolled, and any of that employee's additional dependents will need to be reported on this form.

 

Applicable large employers who must comply with 6056 reporting requirements do not need to file separate forms with the IRS to comply with both the 6055 and 6056 filing requirements if they have all of the required Social Security Numbers. The 6056 filing will satisfy the 6055 reporting obligation.

 

Alternative Reporting Methods

There are alternative methods of reporting under section 6056 that allow employers to file less detailed information in certain situations. These simplified reporting methods are detailed in the final instructions for the IRS Forms which explain in detail the indicator codes to use on the forms based on the optional alternative method the employer has chosen (if they are eligible to use that method). These alternative methods are:

 

1) Reporting Based on Certification of Qualifying Offers. If an ALE has made a Qualifying Offer for all 12 months of the calendar year to one or more of its full time employees, then the employer may use this alternative reporting method for the employees who received the Qualifying Offer. A "Qualifying Offer" is an offer of coverage that meets all of the following criteria:

 

• an offer of minimum essential coverage that provides minimum value;

• the employee cost for employee-only coverage for each month does not exceed 9.69 percent of the mainland single federal poverty line divided by 12; and

• an offer of minimum essential coverage is also made to the employee's spouse and dependents (if any).

 

An ALE reporting under this method may furnish a simplified statement to the employee rather than furnishing a copy of Form 1095-C. However, the alternative statement is not available for an employer that sponsors a self-insured plan with respect to any employee who has enrolled in self-insured coverage under the plan. This is because the employer is required to report that coverage on Form 1095-C.

 

2) Option to Report Without Separate Identification of Full-Time Employees if Certain Conditions Related to Offers of Coverage Are Satisfied (98 Percent Offer Method). An ALE may qualify to use this method if it can certify that it has offered, for all months of the calendar year, affordable health coverage providing minimum value to at least 98% of its employees for whom it is filing a Form 1095-C, and offered minimum essential coverage to those employees' dependents. While this alternative method allows reporting without identifying or specifying the number of full-time employees, it does not exempt the employer from any penalties that might apply for failure to report any full-time employee.

 

Penalties

A reporting entity that fails to comply with the filing and statement furnishing requirements may be subject to penalties of $260 per form (the IRS filing and the individual statement are considered to be two separate forms when applying penalties) for failure to file a correct information return or failure to furnish a correct individual statement. These penalties may be waived if the failure was due to reasonable cause and not willful neglect. Penalties may be reduced if a reporting entity files a corrected return within 30 days after the required filing date.

 

Failure to file electronically without an approved waiver may result in a $260 penalty per form unless reasonable cause can be established.

 

Services Meritain Provides

We have a report for our clients that provides the member information we have in our systems that they'll need to complete the IRS forms.

 

The report will include the following information that is required to complete the IRS Forms:

 

• member name

• Social Security number (if we have it in our system)

• date of birth (to be used if SSN is missing) • the number of months covered

• coverage months (actual months covered)

 

This content is being provided as an informational tool. It is believed to be accurate at the time of posting and is subject to change. It is recommended that plans consult with their own experts or counsel to review all applicable federal and state legal requirements that may apply to their group health plan. By providing this information, Meritain Health is not exercising discretionary authority or assuming a plan fiduciary role, nor is Meritain Health providing legal advice.