Revised January 11, 2017
Local Health Employers: Reporting Requirements for Health Insurance
As a local employer who participates in the Wisconsin Public Employer Group Health Insurance Program, you may be responsible under the federal Affordable Care Act for reporting the provision of minimum essential coverage health insurance to your employees and their covered dependents. Please consult with your tax adviser or attorney to determine your reporting responsibilities under the law.
ETF initially distributed an Employer Bulletin to all employers addressing this issue November 23, 2015. Please note the below:
Q: I know that I need to report dependent Taxpayer Identification Numbers (TIN). How can I obtain a TIN if they are not readily available?
A: A significant number of dependents of employees are missing Taxpayer Identification Numbers (typically a Social Security number) in the MEBS system. ETF is aware that many health plans have been contacting employees to obtain missing TIN’s during the previous year.
Please note the following guidance from the IRS as described in this IRS Tax Tip: Reporting of TINs for all covered individuals is necessary for the IRS to verify an individual’s coverage without the need to contact the individual. If health coverage providers are unable to obtain a TIN after making a reasonable effort to do so, the provider may report a covered individual’s date of birth in lieu of a TIN. A health coverage provider will not be subject to a penalty if it demonstrates that it properly solicited the TIN.
Q: Who is responsible for reporting this information for retirees and continuants?
ETF will provide the 1095-C form to certain non-Medicare retirees and Medicare retirees who cover non-Medicare dependents that participate in a self-funded health plan, which is the It’s Your Choice Local Access Health Plan (formerly the Standard Plan) or the State Maintenance Plan (SMP). ETF is not providing the form to participants in a fully-insured plan or those who have Medicare as their primary coverage.
For COBRA continuants, ETF will provide employers with a full data file of COBRA continuation enrollees. This file will be available to you on ETF’s secured FTP file server if you typically access files using FTP, or emailed to you directly. Once the file is available you will receive a notification email from ETF. ETF anticipates these files will be available soon.