Reporting Requirements

The Affordable Care Act (ACA) imposes new reporting requirements on employers.

Information Reporting on Minimum Essential Coverage

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The Affordable Care Act (ACA) 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 report on the type and period of coverage.  This reporting is designed to assist the Internal Revenue Service (IRS) with enforcing the Individual Shared Responsibility requirements (also referred to as the Individual Mandate).

There are two components to the reporting requirement:

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

Covered individuals include the primary insured (i.e., the employee), 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.  In general, employers sponsoring self-insured plans are responsible for reporting; however, 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, such as “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).

Additional information on the reporting requirements under IRC section 6055 is available in our July 2014 Briefing, which you can find below.


Additional Information
Health Care Reform: 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.