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Home Affordable Care Act Minimum Essential Coverage: Looking Ahead Toward 2016 Reporting

Minimum Essential Coverage: Looking Ahead Toward 2016 Reporting

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by Robert Sheen

Let’s call the details of the Affordable Care Act a work in progress, even still. Since its humble 2010 beginnings, the ACA has evolved based upon the needs of (almost) everyone involved. As we inch toward the close of 2016 and its inevitable health care reporting, the IRS is taking those needs into consideration and making new modifications in a variety of ACA-affected arenas.

As part of the ACA’s constant evolution, the IRS has released proposed regulations regarding Internal Revenue Code Sec. 6055. The proposed regulations include modifications that will require issuers of “catastrophic plans” and “basic health plans” to report to the IRS on such plans.

Effective as of calendar year 2017 (reported on in 2018), catastrophic plans must now be reported through Form 1095-B. These plans were previously not reported on as “qualified health plans”. Additionally, any Basic Health Plans obtained in lieu of Medicaid eligibility must also be reported to the IRS via the state agency that provided the coverage.

The proposed regulations also clarify that if for any given month, an individual is enrolled in more than one minimum essential coverage plan provided by the same reporting entity, reporting is only required for one of the plans under Code Sec. 6055.

Additionally, for certain entities required to report on health coverage to the IRS, a TIN truncation process has been proposed. Clarification around the rules regulating the solicitation of TINs when health accounts are opened was also provided.

These proposed IRS regulations generally apply to coverage received after December 31, 2015, but may also apply to plans after December 31, 2013 (minus catastrophic plans). While some of the changes add an extra step to the reporting process, some steps are removed or better explained, with the intended purpose of streamlining the frequently confusing ACA reporting process.

We’re committed to helping companies reduce risk, avoid penalties, and achieve 100% ACA compliance. For questions about the ACA contact us here.

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