The ACA created two new reporting requirements for calendar year 2015 to be reported in 2016.This will be an annual requirement with data from the prior year being reported to the IRS and individuals in the first quarter of each year. The reports are the Minimum Essential Coverage report (also known as MEC, or the 6055 report) and the Applicable Large Employer report (also known as ALE, the 6056 report or the 1094C and 1095C “C series” reports).
For information on MEC reporting, please refer to ACA Reporting for Under 50 Employees.
The ALE report is a requirement for all groups with more than 50 full-time equivalent employees. Therefore, the ALE report will be mandatory if you qualify as a large employer group. There is a tool available to assist you in determining the size of your group if you are not sure. Please let us know if you need us to send it to you. (Contact information below)
In this memo we hope to clarify:
- What you can expect to receive from GSRMA
- Clarify what parts of the 1095 C must be completed based on the plan the individual is enrolled in under the GSMRA program
- What GSRMA will provide to assist in the reporting process
- What the client’s responsibility will be
The detail on how to complete the forms is not included in this memo. This information can be found in the Employer Reporting Guide created by Alliant Insurance Services, Inc.
PPO Plans (EPO, Gold PPO, Platinum PPO, Silver PPO, High Deductible health plans)
-Considered as self-funded plans, so the MEC reporting obligations belong to the employer.
-Employer must complete Part III (MEC portion) of the 1095-C.
-Considered as fully insured plans.
-Medical Carrier will send the MEC report direct to your individuals using a 1095-B Form.
-You will not need to complete Part III of the 1095-C form for these individuals
How GSRMA Helps
-GSRMA will provide individual 1095-B forms to each district by Jan 31st for each covered member.
-Watch for forms emailed from GSRMA.
-Watch for password to access form.
Completing the forms
-Each 1095-B form can be used to complete the 1095-C forms
- The 1095-B forms provided do not need to be mailed to individuals, it is only being provided so the information is accessible to you to complete the 1095-C form for your members
- The 1095-B forms will not provide information for Part II (lines 14, 15, 16) of the 1095-C form. Each employer will need to populate that information via the TPA they have hire or manually.
- For HMO plans: The 1095-B forms are completed by the insurance carrier and will be sent directly to individuals. Individuals who fall into one of these categories: 1) Part-time employee or 2) non-active employ (such as Cobra, Retiree) do not require a 1095-C form to be completed.
Explanation: A 1095-C form is not required to be sent on fully insured plans for individuals that are not full-time employees.
-Remember to complete Part III of the 1095-C form for all self-funded plans:
- Actives, Cobra, early retirees, and full-time individuals who waived coverage.
- This also includes anyone older than 65 if:
- They are covering dependents that are not Medicare eligible (or)
- They became eligible for Medicare after January 2015 and were covered under your group health plan.
-Who should receive a 1095-C form for fully insured plans?
- Full-time employees covered on the employer plan
- Full-time employees who waived coverage
What you need to do to send reports to individuals
-Complete 1095-C form prior to January 31st.
-Send forms to individuals
- The deadline for providing employee and individual statements is March 31, 2016. Note that employee and individual statements can only be electronically disclosed to the individual or employee if certain rather strict rules for electronic delivery are followed.
- Please remember to mail forms in a secure envelope; similar to what is used for mailing W-2 forms.
-Send forms to: Department of the Treasury Internal Revenue Service Center, Kansas City, MO 64999
Note: Individuals may file their taxes without the 1095-B form but must keep it on file in the event that they are asked to show proof.
**Please note that compliance with these 2015 IRS reporting requirements is on a “good faith” basis**
For information on reporting for under 50 employees, please click here.