2022 ACA 6055/6056 reporting and new guidance

UnitedHealthcare will post 1095-B forms on member portals (e.g., myuhc.com®) for fully insured subscribers prior to the Jan. 31, 2022, filing deadline. Based on recent Internal Revenue Service (IRS) guidance, the ability to post and not mail is now permanent. Resident subscribers in states with the Individual Mandate will have forms mailed unless the member has requested paperless communications.

Forms that are submitted to the IRS or forms for Individual Mandate states (California, Washington, D.C., New Jersey) must be submitted by March 31, 2022. The Rhode Island Tax Revenue Department requires the submission by Jan. 1, 2022.

Key information on UnitedHealthcare and 1095-B forms

  • The 1095-B forms are posted for members and are not mailed to employers. The 1095-C form indicates if the employer offered MEC.
  • If the member requests a printed version of the 1095-B, the member may call the customer service phone number on the back of their ID card. 
  • Employers may not request 1095-B forms for their employees or receive a report of employees who receive a form.
  • The 1095-B form indicates the employer offer of minimum essential coverage (MEC) and the months the employee was covered.
  • Forms that UnitedHealthcare sends to IRS (and state tax revenue where needed) include:
  • 1094-B Transmittal of Health Coverage
  • 1095-B Health Coverage

Key information on Employer requirements for 1095-C forms

  • Applicable Large Employers (ALE) and ASOs must submit the 1095-C forms.  The 1095-C form indicates if the employer offered MEC, if the plan(s) offered was minimum value and affordable, and any months the employee was covered. Both fully insured and ASO 50+ groups are required to furnish the 1095-C and submit it to the IRS by March 31, 2022.
  • Forms that employers send to IRS (and to state tax revenue departments when required) include:
  • 1094-C Transmittal of Employer-Provided Health Insurance Offer and Coverage
  • 1095-C Employer-Provided Health Insurance Offer and Coverage

State reporting requirements

Individuals are no longer subject to a federal IRS penalty if they do not comply with the federal individual mandate coverage requirement under the ACA. However, Washington, D.C., California, New Jersey, Rhode Island and Vermont have initiated their own Individual Mandate requirement for residents. These states have both federal and state tax requirements. UnitedHealthcare submits the FI 1095-B forms to the state tax revenue department and the ALE and ASO must submit the 1095-C to the tax revenue department by the required date. For Rhode Island groups the form must be submitted to the Rhode Island Revenue Department by Jan. 31, 2022, rather than March 31, 2022.

UnitedHealthcare’s approach

  • For fully insured groups, UnitedHealthcare will send the 1095 form to subscribers and to the IRS.
  • Fully insured ALEs are also required to send the IRS 1095-C forms.
  • For All Savers, UnitedHealthcare prepares the 1095-B forms, which the employer then provides to their subscribers and to the IRS.
  • For large ASO groups, the customer prepares the 1095-C form, which they furnish to subscribers and to the IRS.
  • ASO groups may request a custom eligibility report to include month-by-month coverage that is available for a fee.

While the following changes are part of a proposed rule, the government has stated they are effective for 2021 reporting and once finalized for years going forward.

Automatic 30-day extension to provide reporting

The IRS proposes to make permanent the automatic 30-day extension for reporting entities to furnish Forms 1095-B and 1095-C to individuals. This formalizes the approach IRS has used for the past several years. By making this extension permanent, the IRS eliminates the need for reporting entities to request, and the IRS to process, a substantial number of extensions each year while providing additional time for reporting entities that need it.

The proposed rule does not extend the deadline for reporting entities to file Forms 1095-B, 1094-C or 1095-C with the IRS. However, the IRS already permits entities to request a 30-day extension.

Alternative (electronic) delivery method for Form 1095-B

The IRS proposes to permanently allow health insurers to furnish Form 1095-B only upon request instead of having to send the form proactively to all subscribers and to do so electronically rather than as a hard copy.

  • Reporting entities must prominently display a clear and conspicuous notice on their website informing individuals how to request a copy, including an email address, a physical address, and phone number. This notice must be displayed until October 15 of the calendar year following the applicable tax year.

The proposed rule does not allow ALEs to use the alternative method of furnishing Form 1095-C to full-time employees who are enrolled in a self-insured plan.

Elimination of transitional good faith relief

The IRS believes that because reporting entities have had six years to implement reporting requirements, there is no longer a need to provide transitional good faith relief for furnishing statements to individuals under Sections 6055 and 6056. Such relief covered incorrect or incomplete information, including tax identification numbers (TINs) or dates of birth, reported on information returns or statements, but it did not cover failure to file timely. Accordingly, the IRS is discontinuing transitional good faith relief with respect to furnishing statements after tax year 2020.

For questions, please contact your broker or UnitedHealthcare representative.