Update on 1095-B and 1095-C forms, including suppressed 1095-B mailings

Based on recent guidance for the Affordable Care Act, most printed 1095-B forms will have been suppressed and not mailed in January. These were previously sent to fully insured group subscribers. However, since the forms are no longer required for federal tax purposes, they are not required to be mailed in January like they have in the past.

UnitedHealthcare will continue to make these forms available on most member portals. Some states have initiated their own individual-mandate requirement for residents of those states. UnitedHealthcare will continue to mail 1095-B forms to subscribers in states where required for individual mandates, as well as in situations where social security number (SSN) solicitation is needed for missing SSNs.

For fully insured plans, UnitedHealthcare will be sending the 1095-B forms to the Internal Revenue Service (IRS) by March 31, as required. Fully insured and self-funded employers with 50 or more full-time-equivalent employees (FTEs) are required to provide the 1095-C to employees and to send the forms to the IRS by the required dates – Feb. 28 for mail and March 31 for electronic submission. Employers with 49 or fewer FTEs are not required to submit a report to the IRS.

Although no longer needed for reporting federal taxes, a member may obtain the 1095-B on the member portals or by calling the number on their ID card. Additional mail and e-mail request options will be forthcoming, and notices and links will be placed on member portals with instructions on how to request via these other methods.

State requirements for individual coverage and associated reporting requirements

Individuals are no longer subject to a federal IRS penalty if they did not comply with the shared-responsibility requirements of the ACA, sometimes referred to as the Individual Mandate. The penalties have been removed for those who do not have health insurance coverage.

Reminder: New Jersey and D.C. implemented state individual mandate requirement for 2019 

Although the federal level penalties have been removed for those who do not have health insurance coverage, some states have initiated their own individual-mandate requirement for their residents. 

Individuals who have resided in New Jersey or Washington, D.C. for any time during 2019 will be required to report if and when they had minimum essential coverage (MEC) on their New Jersey or D.C. tax returns in 2020.

UnitedHealthcare mailed out the 1095-B forms to N.J. and D.C. residents in January and will submit the required 1095 forms to the state tax departments by the deadlines below for fully insured groups:

  • New Jersey Tax Department by March 31, 2020
  • Washington, D.C., Tax Department by June 30, 2020

Fully insured ALEs and self-funded groups also will be required to submit copies of either the 1095-B (groups of 1-50 FTE) or 1095-C (50+ FTE) to the state of New Jersey or D.C. tax departments. There are penalties for individuals who have resided in New Jersey or D.C. beginning with the 2019 calendar year if they do not have insurance coverage as required by the state. 

If needed, a self-funded group may request a custom eligibility report to include month-by-month coverage that is available for a fee. The group may also request a report for New Jersey or D.C. residents. For 2020, the report will include current residence only.

Several other states have enacted new legislation that adds an individual mandate and penalty for 2020 coverage that will require state reporting in 2021. UnitedHealthcare will send out additional information as the states publish regulations to implement the new reporting requirements.

Summary of UnitedHealthcare’s approach

For fully insured groups: UnitedHealthcare will send the 1095 form to the IRS and where required to the N.J. or D.C. tax departments by the due dates.

For fully insured ALEs: For fully insured ALEs: the group is required to report 1095-C information to the IRS and to N.J. or D.C. state tax departments by the due dates. Except for part time employees, ALEs must still furnish copies of the 1095-C form to each subscriber. 

For All Savers®: UnitedHealthcare prepares the 1095-B information, which the employer then provides to the IRS and to the N.J. or D.C. tax departments by the due dates. 1095-B forms must also be furnished to N.J. and D.C. subscribers and to other subscribers upon request.

For large self-funded groups: The customer prepares the 1095-C form, which they then submit to subscribers, to the IRS and where required to the N.J. or D.C. tax departments by the due dates. Except for part-time employees, ALEs must still furnish copies of the 1095-C Form to each subscriber.

Brokers: Contact your UnitedHealthcare representative with any questions. Customers: Contact your Broker or UnitedHealthcare representative.