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Legislative Update - Minimum Essential Coverage Reporting

Minimum Essential Coverage Reporting: IRS Releases Final Forms and Instructions for 2018 Forms 1094 and 1095 B and C

The IRS has released the final Forms 1094-B, 1095-B, 1094-C, and 1095-C for calendar year 2018 reporting. Employers are required to report in early 2019 for calendar year 2018. You can find the forms for calendar year 2018 reporting here:

1094/1095-B Instructions
Form 1094-B (transmittal)
Form 1095-B
1094/1095-C Instructions
Form 1094-C (transmittal)
Form 1095-C

What Changed?
For calendar year 2018, the 6055 and 6056 reporting process is largely unchanged. One notable difference seen in both the 1095-B and 1095-C forms is the box formatting for entering the names of the Responsible Individual and Covered Individuals. Prior versions of these forms included one line for a person’s first name, middle initial, and last name, but for calendar year 2018, there are separate boxes for each piece of information. This change may be significant for an employer who has developed programming to autofill these forms.
 
For purposes of determining affordability of employer-sponsored coverage when using the Qualified Offer method, the instructions note inflation adjustments to the 9.5% threshold.  This percentage is 9.56% for plan years beginning in 2018, which is a drop from 9.69% in 2017. (See IRS Publication for details.)

Who Is Required to Report?
1094-B and 1095-B: These forms are used by insurers, self-insuring employers, and other parties that provide minimum essential health coverage (regardless of size, except for large self-insuring employers) to report information on this coverage to the IRS and to covered individuals. Note: Self-insuring employers with less than 50 full-time or full-time equivalent employees will use these forms to report information on coverage to the IRS and to covered individuals. Self-insuring employers with 50 or more full-time or full-time equivalent employees will use the C forms—see below.
 
1094-C and 1095-CApplicable large employers (generally those with 50 or more full-time employees, including full-time equivalents or FTEs) will use Forms 1094-C and 1095-C to report information to the IRS and to their employees about their compliance with the employer-shared responsibility provisions (“pay or play”) and the health care coverage they have offered. Employers subject to both reporting provisions (generally self-insured employers with 50 or more full-time employees, including FTEs) will satisfy their reporting obligations using the C Forms. 

Information Reporting Deadlines 
The upcoming deadlines for submitting Forms 1094 and 1095 B or C are as follows:
 
To the IRS:
If filing on paper – February 28, 2019
If filing electronically – April 2, 2019

Any employer who would like to file electronically should refer to the IRS for more information on the AIR Program, which requires at least 30 days for testing for first-time users. Please note that employers submitting more than 250 forms must file electronically.
 
To Individuals:
Both Form 1095-B and 1095-C are due to the person identified as the “responsible individual” by January 31, 2019.
 
Questions:
If you have any questions, please contact your MedCost Benefit Services Account Manager or MedCost Compliance at Compliance@medcost.com.