Section 6055 requires health insurers and sponsors of self-insured plans to report on this coverage to the IRS annually. The reporting to both individuals and the IRS for 2015 is due in early 2016. It also requires insurers and self-insured plans to report to their MEC recipients, so the individuals can report that coverage when filing their federal taxes.
The 6055 reporting requirement has two goals. It helps individuals verify that they have MEC for purposes of satisfying the Individual Shared Responsibility requirement. At the same time, it enables the IRS to crosscheck that information with insurers or self-insured plans.
Entities subject to 6055 reporting are health insurance issuers, sponsors of self-insured plans, government sponsored programs, such as Medicaid, and providers of other arrangements designated as MEC, such as high-risk pools.
The final rule states that self-insured employers are responsible for reporting this information to the IRS. Humana will provide reporting to the IRS for fully insured groups. If a self-funded employer needs information on covered members and their coverage dates for a calendar year to meet their part of their reporting obligation, a report of covered individuals can be requested through their Humana representative.
Information required to be reported to the IRS by health insurers and sponsors of self-insured plans who provide minimum essential coverage:
- The name, address and Employer Identification Number (EIN) of the reporting entity required to file the return.
- The name, address and Taxpayer Identification Number/Social Security Number (or date of birth if a TIN/SSN is not available and applicable requirements are met), of the responsible individual, except that reporting entities may but are not required to report the TIN/SSN of a responsible individual not enrolled in coverage.
- The name and TIN/SSN (or date of birth if a TIN/SSN is not available and applicable requirements are met), of each individual who is covered under the policy or program.
- Whether the coverage is a Qualified Health Plan (QHP) provided through the Small Business Health Options Program (SHOP) and the SHOP’s unique identifier. Information required to be reported to responsible individuals:
- The phone number for a person designated as the reporting entity’s contact person and policy number, if any.
- All information required to be shown on the Section 6055 return for the responsible individual and each covered individual listed on the return.
Important Note: While the final rule allows reporting of birthdate if SSN cannot be obtained, it also requires the reporting entity (insurer or self-funded employer) to make two attempts to secure the SSN for reporting purposes. This will require Humana to contact the primary insured to obtain missing social security numbers for them or their dependents for all fully insured groups. Humana plans to start this outreach mid-year in 2015 and provide employers with a courtesy advanced notification. You can help by being proactive now in encouraging employees to provide this information up front at enrollment or open enrollment.