IRS officials described when employers themselves have to fill out full information on all health plan enrollees along with months enrolled, and when employers can hand that over to another entity, such as an insurer.
Most employers offer minimum essential coverage to employees; the purpose of Section 6055 reporting is to demonstrate that they are doing that, thereby shielding both themselves and their employees from having to pay penalties, said Jeffery Rodrick, a senior technician reviewer at the IRS. He was speaking on Sept. 9, in an IRS webinar.
MEC is defined as (1) government coverage, (2) employer group health plan under ERISA; but not coverage that’s solely excepted benefits; and (3) individual coverage; (4) grandfathered plans; (5) other plans recognized by HHS as MEC, such as some student health plans.
All employer-sponsors of coverage must report who they offered coverage to. Self-insured employers must also report on who actually accepted coverage.
Employers that sponsor coverage must report offers of coverage to the IRS. If the employer is small (100 or fewer employers in 2015, and 50 or fewer in 2016 and thereafter) the employer mandate is not in effect, and the insurance company will handle the reporting. If the small employer sponsors a self-insured health plan, there is no insurer, so the employer must handle it.
Applicable large employers have to make offers of coverage or pay penalties. If an ALE is insured by an insurer, it needs to fill out part one and part two about itself and the employees it offered coverage to. Its insurer will fill out part three, on who is actually enrolled under the plan.
If an ALE is self-insured, it will have to fill out parts one, two and three of the form 1095-C, including the section on who is actually enrolled in coverage, and the time period they were enrolled, down to the month, Stephen Tackney, deputy associate chief counsel for the IRS, told attendees. Smaller companies will fill out the shorter 1095-B form, he said.
Employer-sponsored supplemental coverage to Medicare and HRA coverage supportive to an MEC plan do not need to be reported; only the primary MEC coverage, the speakers stated.