Minimum Essential Coverage (MEC) (Section 6055) and Large Employer (Section 6056) reporting are required by the Affordable Care Act (ACA) to help the Internal Revenue Service (IRS) administer compliance with the individual and employer mandates.
The insurance carrier is responsible for MEC reporting on individuals covered under fully insured health plans. Employer clients are responsible for MEC reporting on individuals covered under their self-funded plans. To complete this reporting, Social Security Numbers (SSNs) are required for all covered employees and dependents. Insurance carriers (for insured plans) and employers (for self-funded plans) must make up to three “reasonable attempts” to acquire any missing SSN data.
In addition, employers with 50 or more full-time and/or full-time equivalent employees are responsible for completing the Large Employer reporting on the group health coverage they offer to full-time employees and their dependents, regardless of funding type.
Reporting Forms and Deadlines for fully insured health plans
Insurance carriers will use Form 1094-B (transmittal/cover sheet) and Form 1095-B to complete the Minimum Essential Coverage reporting. If Large Employer reporting applies, you, as the employer, will use form 1094-C (transmittal/cover sheet) and 1095-C (parts I & II) to complete the reporting.
You may want to communicate to your employees that they will be receiving separate reporting forms – a 1095-B from the insurance carrier and a 1095-C from your organization – in early 2016.
Reports must be sent to each full-time employee and be postmarked by January 31, 2016. Reports are due to the IRS by March 31 if filing electronically.*
Reporting Forms and Deadlines for self-funded health plans
As a self-funded plan sponsor, your organization is responsible for completing Minimum Essential Coverage (MEC) reporting for individuals covered under your self-funded group health plan during the 2015 calendar year. To complete this reporting, you will need Social Security Numbers (SSNs) for all covered employees and dependents. In addition, if you have 50 or more full-time and/or full-time equivalent employees, you are responsible for completing the Large Employer reporting on any group health coverage that you offered to your full-time employees and their dependents in 2015.
Self-funded employers will use Form 1094-C (transmittal/cover sheet) and Form 1095-C to complete both sets of reporting.
You may want to communicate to your employees that they will be receiving a 1095-C reporting form in early 2016.
*Fewer than 250 forms can be mailed to the IRS if postmarked by February 28.
For more information on sample employee communication and reporting resources, please email compliance@teambim.com.