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Mandatory 6055/6056 Reporting Right Around The Corner

The Internal Revenue Service (IRS) recently released the final IRS forms to be used for the 2015 calendar year to complete the mandatory 6055 and 6056 reporting that was added under the Affordable Care Act. These mandatory reporting requirements will be used to enforce the individual mandate, determine if someone is eligible for a premium tax credit and to enforce the shared responsibility provision under the employer mandate. 

 

The following chart has been developed to provide you with an overview of the final requirements. As you prepare for this reporting, please know that Meritain Health will have a report available to assist you with your 6055 reporting requirement.

 

60556056

What is the need for this reporting?

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)

 

Note: Please see below for other types of coverage that are also considered MEC.

Applicable Large Employers (ALEs) who employ 50 or more FTEs and must comply with the employer mandate
When is the reporting due?

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

 

To individuals by January 31 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 28 if filing a paper return or by March 31 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.

 

On December 28, 2015, the IRS announced it would be extending these deadlines for the 2015 calendar year reporting. Please click here for more information.

The deadline for filing each form is the same. Please refer to the dates at left.

 

On December 28, 2015, the IRS announced it would be extending these deadlines for the 2015 calendar year reporting. Please click here for more information.

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: You 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, you must explain why (for example, the employee was part time during that month).


We know you may still have some unanswered questions. Provided below are some frequently asked questions that we would like to share with you to hopefully answer some of your questions.

 

My plan year runs on an off calendar year, do I still need to report information based on a calendar year?

Yes. Reporting is required on a calendar year basis regardless of your health plan’s plan year.

 

I did not have to comply with the employer mandate in 2015. In fact, I do not have to comply until my 2016 plan year. Are you sure I have to comply with the 6056 reporting requirements for the 2015 calendar year?

Yes. ALEs with 50 or more FTEs must complete the applicable 6056 form for the 2015 calendar year even if they have taken advantage of the safe harbor for this year. These ALEs will not be assessed any penalties based on what they report for the 2015 calendar year, as they have until 2016 to comply with the employer mandate.

 

Is anything required of ALEs who will be filing electronically?

Yes. Filers submitting the 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 must use approved software to perform the communications test. Testing is required for the first year only to ensure that the IRS can receive the electronic returns and the filer can retrieve acknowledgements.

 

What types of coverage are considered to be MEC for purposes of 6055 reporting?

MEC 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.

 

What must be reported if an individual is covered by more than one MEC plan?

If an individual is enrolled in more than one type of MEC plan, reporting is required of only one of the types if one of the following rules applies:

  • 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.)

 

I am an applicable large employer that must comply with the 6056 reporting requirements: do I really have to file separate forms with the IRS to comply with BOTH the 6055 and 6056 filing requirements?

It depends. If you are a plan that has all the required SSNs, your 6056 filing will satisfy your 6055 reporting obligation and a separate 6055 filing will not be required. However, if you are missing SSNs for individuals covered under your health plan who are not employees, you will be required to file a separate 6055 form. All employee family members that are covered individuals through the employee’s enrollment (for example, because the employee elected family coverage) must be included on the same form as the employee (or individual to whom the offer was made). If you find that you are missing one dependent’s SSN, this will necessitate the use of the 6055 form and the employee and any additional dependents must also be reported on that form. Please note that the employee would still need to be reported on the 6056 form as that form reports on offers of coverage and the 6055 form reports on actual coverage.

 

Under the 6056 reporting requirement, am I required to report on COBRA participants?

Yes. COBRA offered to active employees (e.g., those who had a reduction in hours) will be reported as an offer of coverage. Offers of COBRA coverage for termed employees will be reported as no offer.

 

For the 6055 reporting, we are required to include information on ALL members enrolled in our health plan. How do they define a member?

A member is basically anyone who was covered under your health plan at least one day during the calendar year. This means that in addition to providing information on your covered employees and their dependents, you also must report on retirees, independent contractors, COBRA participants, non-employee board members, members covered by a qualified medical child support order (QMCSO), deceased individuals who were previously covered and any other individual who is enrolled in your plan.

 

What happens if I do not have a member’s SSN?

Insurers and self-funded employers are required to collect and report SSNs (among other required data elements) for all covered individuals, which includes members and their dependents for purposes of the 6055 and 6056 reporting that is required in 2016. A member’s date of birth may be used in place of their SSN if three collection attempts had been made to collect their SSN and were unsuccessful.

 

Plans can make collection attempts by phone, in person or in writing (including asking for this information on an application). If the plan is already in possession of an individual's SSN for other purposes, the plan may use the SSN for 6055/6056 reporting.  

 

Can I make the three attempts whenever I want, or is there a timeline that must be followed?

There is a timeline that must be followed. Below is the timeline you need to be aware of when attempting to obtain the SSNs:

  • Initial attempt. For self-funded plans, the initial attempt is made when the relationship with the member begins, or in other words, the initial collection attempt may be made at the time of an individual's hire. For fully insured plans, this would be when the member is first enrolled for coverage. If the SSN has been provided to you for other purposes, you may use that SSN to satisfy this requirement.
  • First annual attempt. The first annual collection attempt is required by December 31 of the year in which the relationship with the member began. If the relationship begins in December, the first annual collection attempt will be required by January 31 of the following year. This first attempt is satisfied with the open enrollment period and accompanying forms that ask for the individual's SSN.
  • Second annual attempt. If the SSN is not received, the last collection attempt must be made by December 31 (or January 31) of the following year. This is satisfied by the open enrollment period and accompanying forms that ask for the individual's SSN.

 

Will requesting a member’s SSN on the enrollment form count as an attempt?

Yes. The distribution of an enrollment form that requests a member's SSN at open enrollment each year will satisfy these required attempts. The Meritain Health enrollment form currently requests each member's SSN. While this information is requested on the enrollment form, it is not always provided. Plan sponsors should consider making this a mandatory field that must be completed to encourage members to include this information when they complete their enrollment form.

 

Is it possible to get an extension for filing the required forms?

Yes. IRS Form 8809, which has traditionally been used to file for extensions for other informational returns such as the W2, has been revised to include 6055 and 6056 reporting. A 30-day extension is available to file the Forms 1094 and 1095 by filing form 8809 on or before the form’s due date (February 29, 2016, if Form 1094 or 1095 will be filed on paper and March 31, 2016, if Form 1094 or 1095 will be filed electronically). Additional extensions of no more than 30 days may be granted if there are extenuating circumstances.

 

What information will Meritain Health provide to assist in completing the 6055/6056 reporting?

Due to the content requirements of each report, we are only able to assist you with your 6055 filing requirement. Our report will include the name of the covered employee and their coverage level (single, family, etc.), any applicable dependent information, the appropriate coverage months for both the employee and any covered dependents, as well as a date of birth and SSN for each enrolled member provided we have that information in our system.

 

Is there a sample report available?

Yes, you may obtain a sample report by requesting one from your client relationship manager. While the content of the reports will be the same, the layout varies depending on which platform is used to administer each plan.

 

Where can I find the final forms and instructions?

You can find the final forms and their instructions here:

Are you able to quickly summarize each form for me?

The following summary chart breaks down each form, why it is required, who is required to use it and the appropriate recipient of each.

 

Form Number and NamePurposeInitiatorRecipient
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 copies of each 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.

 

Compliance Corner is being provided as an informational tool. 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 publication and any attachments, Meritain Health is not exercising discretionary authority over the plan and is not assuming a plan fiduciary role, nor is Meritain Health providing legal advice.