Must self-insured employers file health coverage information returns?


Your company sponsors a self-insured health plan for employees. Do self-insured employers need to file an annual health coverage information return under the Patient Protection and Affordable Care Act (ACA)?


Yes, all employers that provide self-insured health coverage to their employees must file an annual health coverage information return for coverage provided, regardless of the employer’s size. Filing requirements are as follows:

  • Form 1095-B, Health Coverage, accompanied by a Form 1094-B transmittal, must be sent to the IRS.
  • Those with more than 250 Forms 1095-B must e-file; those with fewer than 250 are encouraged, but not required, to do so.

A copy of the Form 1095-B must be provided to the responsible individual, who is generally the primary insured, employee, parent, or uniformed services sponsor. It may be furnished electronically.

Information reported to the IRS must include the following:

  • The name, address, and employer identification number of the provider;
  • The responsible individual’s name, address, and taxpayer identification number (TIN), or date of birth if a TIN is not available. If the responsible individual is not enrolled in the coverage, providers may, but are not required to, report the TIN of the responsible individual; and
  • The name and TIN, or date of birth if a TIN is not available, of each individual covered under the policy or program and the months for which the individual was enrolled in coverage and entitled to receive benefits.

Applicable large employers. Applicable large employers (ALEs) that provide self-insured coverage must report on Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, which combines reporting for two provisions of the Patient Protection and Affordable Care Act (ACA), instead of Form 1095-B. ALEs should review Publication 5196, Reporting Requirements for Applicable Large Employers, the IRS advises.

Health coverage providers must file the information returns with the IRS and furnish statements to individuals starting in 2016, reflecting coverage information in calendar year 2015. The IRS also suggests that employers providing self-insured coverage review IRS Publication 5125, Responsibilities for Health Coverage Providers.

Source: IRS Health Care Tax Tip 2015-42, July 21, 2015.

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