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Employer reporting….more guidance

Carriers often release alerts or guidance on specific issues on health care reform. Cigna released guidance on Minimum Essential Coverage reporting requirements.

Minimum Essential Coverage (MEC) reporting is required to help the Internal Revenue Service (IRS) administer compliance with the individual mandate. All insurers and self-funded group plan sponsors are required to start reporting on the individuals covered under their insured health plans, starting with coverage in 2015. While these reporting requirements do not begin till 2016 for the 2015 year, certain components of the law require actions this year.

Because Social Security Numbers (SSNs) and Tax Identification Numbers (TINs) are the main individual identifying data used by the IRS, reporting entities are required to make “reasonable attempts” to obtain this sensitive data from those individuals’ whose SSNs/TINs they don’t have on file.

“Reasonable attempts” are defined as three attempts to obtain the SSN/TIN, and may include electronic, paper, telephonic, etc. outreach*. These attempts must be made by certain dates, starting this year. The outreach is only to each employee or subscriber and their dependents whose SSN/TIN the reporting entities (fully insured business and the client for self-funded business) don’t have, starting with those enrolling/enrolled in 2015 coverage. For example:

  • First Attempt:

o    Current or previous enrollment can satisfy the first attempt, if applications have or had space for each employee and dependent to provide their SSNs/TINs. Enrollment forms often do request the SSN.

o    If current or previous enrollment does not solicit SSN/TIN, a separate outreach must be made in 2014 to obtain employee and dependents’ SSNs/TINs. Since enrollment forms may request the SSN, this separate first attempt is not required for our customers covered under fully insured plans.

  • Second Attempt

o    A separate outreach must be made before December 31, 2014

  • Third Attempt

o    A separate outreach must be made before December 31, 2015

If the SSN/TIN is not obtained after making the three attempts, reporting entities may use the date of birth for any of those covered individuals.