Note: On Dec. 2, 2019, the IRS announced extended deadlines for certain 2019 Minimum Essential Coverage (Section 6055) and Large Employer Shared Responsibility (Section 6056) reporting required to be completed in early 2020. Specifically, 1095 Forms sent to individuals are now due by March 2, 2020. Read IRS Notice 2019-63 for more details.
Welcome to the Reporting Requirements Toolkit
There are two distinct sets of reporting requirements to help the Internal Revenue Service (IRS) administer compliance with the employer and individual mandates – the Large Employer Reporting and Minimum Essential Coverage (MEC) Reporting requirements. It’s important to understand the impacts of these responsibilities because they vary based on group plan size and how plans are insured or funded.
Large Employer Reporting – all applicable large employers must report to the IRS on the medical coverage they offer in compliance with the employer mandate. The reporting is due annually.
Minimum Essential Coverage (MEC) Reporting – all insurers of health plans offering minimum essential coverage must report on all individuals covered under these plans. Among other things, this information will help the IRS confirm the reported individuals are compliant with the individual mandate.
Insurers and employers of self-insured medical plans must report annually on every covered individual, including dependents.
To ensure the reporting includes identifying data for the IRS, these reporting entities must make “reasonable attempts” to capture social security numbers (SSNs) for all covered individuals. If not provided during enrollment, a written communication must be sent to the “responsible person” who may provide the missing SSN information. In other words, the covered employee would receive the request for missing SSNs of any dependents.
Social Security Numbers with Cigna
Social Security Numbers (SSNs) and Tax Identification Numbers (TINs) are sensitive personal health information, and must be handled carefully and confidentially. At Cigna, we are committed to the responsible management, use and protection of our customers’ personal information, including SSNs/TINs. This includes both how we share, and receive data with our clients. Therefore, not all users of Cigna's secure client websites will have access to view this sensitive personal data. Any user that logs into a secure Cigna client website that cannot access SSN data from the eligibility report should work with their organization’s Plan/Primary Administrator.
Cigna data is obtained differently depending upon which website our clients use, the data is available for download via the following eligibility reports:
Cigna Global Health Benefits Clients should contact their CGHB Client Manager for data inquiries.
These reports include every individual covered under a Client’s group medical plan. They also include SSN data. If there is a blank field, or the field has all zeros, Cigna does not have a SSN on record. Cigna might also have an invalid SSN, which for reporting and outreach is the same as having no SSN on record. There are a few rules for identifying invalid SSN’s outlined in this chart:
|2019 Reports||Original Deadline*||Extension Date|
Forms Sent to Individuals
January 31, 2020
March 2, 2020
Forms Filed with the IRS
Forms 1094-B and 1095-B
Forms 1094-C and 1095-C
February 28, 2020 – paper
March 31, 2020 – electronic
IRS Requirements and Sample Communications
The following are samples of the cover letters Cigna will include with 1095-B mailings to customers of insured health plans.
Additional compliance action is required for Minimum Essential Coverage reporting by insurers or employers of self-insured health plans. Because SSNs are a key identifier for the IRS, reporting entities are required to make up to three “reasonable attempts” to obtain missing SSNs. Enrollment can be considered the first attempt as long as there’s a place for enrollees to give/confirm SSNs for themselves and dependents. If SSN/TIN is not obtained at enrollment, a separate outreach must be made by December 31 preceding the year being reported on. For those still missing SSN data after two outreach attempts, the third attempt must be made before December 31 of the year being reported on.
Basic SSN Outreach Schedule
Outreach for obtaining SSNs is an annual requirement in conjunction with reporting on any given calendar year of coverage.
Cigna SSN Outreach to the "responsible individual" covered under our insured medical plans, who can provide SSNs for themselves and/or their dependents began in August and will be conducted on a staggered basis throughout the remainder of the calendar year.
We hope to work with our insured clients to obtain as many SSNs as possible during enrollment and via standard eligibility reporting. We understand the disruption this type of outreach could cause to our clients and their benefits resources area.
View Cigna's message for outreach for insured group health plans
View Cigna's message for outreach for Individual and Family plans
Please visit Informed on Reform, our web-based resource for critical information you need to know about the Patient Protection and Affordable Care Act (PPACA). For a comprehensive overview of the law’s other employer administrative responsibilities, please be sure to look into our Reporting Requirements..
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