2021 ACA 6055/6056 reporting and state Individual Mandates

For tax year 2020, UnitedHealthcare will post 1095-B forms on member portals (e.g., myuhc.com®) for fully insured subscribers prior to the Jan. 31, 2021, filing deadline. Resident subscribers in the states with the Individual Mandate (California, D.C., New Jersey and Rhode Island) will be mailed forms unless the member requests paperless communications.

ACA 6055/6056 reporting 

Funding

ACA 6055/6056 Reporting  

Individual Mandate Penalty Eliminated 

ACA 6055/6056 Reporting and State Individual Mandate Reporting  

Five States – California, Washington, D.C., New Jersey, Rhode Island, Vermont* 

Fully Insured

Members – UnitedHealthcare will post 1095-B forms on member portals by Jan. 31, 2021, for subscribers who were eligible for coverage for at least one month in 2020.  

IRS – UnitedHealthcare will transmit the forms to the IRS by the March 31, 2021, required date.  

Members – UnitedHealthcare will furnish residents of applicable states with the 1095-B form. This form is also posted on the portal.   

IRS – UnitedHealthcare will transmit the 1095-B forms to the State Tax Department, as well as to the IRS by the March 31, 2021, required date. (Washington, D.C.’s deadline is June 30, 2021.) 

Fully Insured ALEs

Employees – Fully insured Applicable Large Employers (ALE) with 50+ full-time equivalent (FTE) employees are required to furnish their employees with a 1095-C by Jan. 31, 2021. 1095-C is required even though UnitedHealthcare has provided the 1095-B.  

IRS – Fully insured employers must transmit the forms to the IRS by Feb. 28, 2021, for paper or March 31, 2021, for electronic. 1095-C is required even though UnitedHealthcare has transmitted the 1095-B. 

Resident Employees – UnitedHealthcare will furnish residents of the applicable states with 1095-B forms. Employers are required to provide 1095-C forms. Individuals must report coverage to the state on their tax returns.   

State Tax Department – Fully insured employers must transmit the 1095-C forms to the State Tax Department by March 31, 2021, as well as to the IRS. (Washington, D.C.’s deadline is June 30, 2021.) 

ASO ALEs

Employees – ASO employers must provide their employees, by Jan. 31, 2021, with: 

  • 1095-B if they are a small employer with one to 49 FTEs (includes All Savers).
  • 1095-C if they are an ALE with 50 or more FTEs.

IRS – Employers are required to transmit 1095-Cs to the IRS by Feb. 28, 2021, for paper or March 31, 2021, for electronic. (This deadline is Feb. 28, 2021, for the paper method.) 

Resident Employees – ASO employers must provide employees resident of an applicable state by Jan. 1, 2021, with:

  • 1095-B if they are a small employer with one to 49 FTEs (includes All Savers®).
  • 1095-C if they are an ALE with 50 or more FTEs.

Individuals must report coverage on their state tax returns. 

State Tax Department – Employers are required to electronically transmit 1095-C to the State Tax Department by March 31, 2021. 

*Vermont implements an Individual Mandate beginning with 2020. However, for reporting purposes, the state follows what is currently being done for federal Affordable Care Act (ACA). No special state reporting is required. (See Vermont section below for more details.)

Key information on 1095-B and 1095-C forms

  • 1095-B forms are posted for members and are not mailed to employers. 
  • Employers may not request 1095-B forms for their employees or receive a report of employees who receive a form.
  • 1095-B forms indicate the employer offer of minimum essential coverage (MEC) and the months the employee was covered.  
  • 1095-C forms indicate if the employer offered MEC, if the plan(s) offered was minimum value and affordable, and any months the employee was covered.   
  • If the member wants a printed version of the 1095-B, the member may call the customer service phone number on the back of their ID card. 
  • Forms that are sent to IRS include:
    • 1094-B Transmittal of Health Coverage
    • 1095-B Health Coverage
    • 1094-C Transmittal of Employer-Provided Health Insurance Offer and Coverage 
    • 1095-C Employer-Provided Health Insurance Offer and Coverage

New state requirements for Individual coverage and associated 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, some states have initiated their own Individual Mandate requirement for residents of those states. 

In 2019, New Jersey and Washington, D.C., added an Individual Mandate and penalties; in 2020, California, Rhode Island and Vermont also added a mandate and penalties. For these states, there are now both federal and state tax requirements. 

Currently, Vermont is not requiring special reporting to the employee or the state. UnitedHealthcare complies with the Vermont Individual Mandate by making the 1095-B available to all subscribers on the member website or by calling the number on health plan ID cards. Since 6055 reporting is still an active federal regulation, no submission to the state is required. 

The UnitedHealthcare approach

  • For fully insured groups, UnitedHealthcare will send the 1095 form to subscribers and to the IRS.
  • Fully insured ALEs are 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 then submit 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 via Underwriting.

Please contact your broker or UnitedHealthcare representative with questions.