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Information Reporting on Minimum Essential Coverage

The Affordable Care Act added significant new reporting requirements to the Internal Revenue Code (IRC). IRC section 6055 requires health insurance issuers, employers providing self-insured group health coverage and others that provide minimum essential coverage (MEC) to annually report on the type and period of coverage.

There are two components to the reporting requirement:

  • Reporting to the IRS on each covered individual.
  • Furnishing of a statement to each responsible individual identified in the IRS reporting.

Covered individuals include the primary insured (i.e., the employee or retiree), his or her spouse and any dependents.

Responsible individuals include the primary insured (i.e., the employee or retiree), parent or other related person named on an application who enrolls one or more individuals, including him or herself, in MEC.

For employers with fully-insured plans, the issuer or carrier is responsible for reporting on Forms 1094-B and 1095-B.Employers sponsoring self-insured plans are responsible for reporting on Forms 1094-C and 1095-C. Certain exceptions apply for multiemployer plans, plans maintained by an employee organization and employers participating in a MEWA.

No obligation exists to report on coverage that is not MEC, including “excepted benefits” (e.g., limited scope dental and vision care) and health savings accounts. In addition, there is no obligation to report on MEC that supplements the primary plan of the same plan sponsor or that supplements government-sponsored coverage (e.g., Medicare).

Additionally, California, Massachusetts, Rhode Island, New Jersey, Vermont and the District of Columbia have enacted state-level reporting requirements.

Additional Information

IRS Provides Clarification on Solicitation Requirements for Missing SSNs/TINs
     The IRS has clarified the reasonable steps filers must take to solicit missing SSNs/TINs.

IRC §6055 Information Reporting on Minimum Essential Coverage
     This Briefing outlines the reporting requirements under Internal Revenue Code section 6055, including the information to be reported, timing for filing and penalties for noncompliance.

IRS: Questions and Answers on Information Reporting by Health Coverage Providers (Section 6055)

IRS: Information Reporting by Applicable Large Employers