Reporting basics for employers vs. Cigna

Employers have a single IRS Form 1095-C for reporting data on the employer mandate, individual mandate or both. For large employers, a Form 1095-C must be completed for each employee being reported. A single Form 1094-C must accompany the set of Forms 1095-C when filing to the IRS. Small employers with fully insured plans do not have applicable data to report. However, if small employers self-insure their medical plans, Form 1095-B must be completed for each individual being reported. A single Form 1094-B must accompany the set of Forms 1095-B when filing to the IRS.

Review Final IRS Instructions for Forms 1094-C and 1095-C
("Applicable large employers", self-insured plans complete the entire Form 1095-C)

Review Final Form 1094-C (a transmittal/cover sheet) to the IRS

Review Final Form 1095-C to both the IRS and individuals
(If its plan is insured, the applicable large employer will only complete Parts I and II of Form 1095-C)

Review Final IRS Instructions for Forms 1094-B and 1095-B
(Insurance carriers and small employers with self-insured plans use these forms)

Review Final Form 1094-B (a transmittal /cover sheet) to the IRS

Review Final Form 1095-B to both the IRS and individuals

* Large employers are those with 50 or more full-time or full-time equivalent employees.
** Small employers are those with 1-49 full-time or full-time equivalent employees.

Large employers have to report annual data that includes: a list of all full-time and full-time equivalent employees, when medical coverage was offered to these employees and their dependents, and the premium costs on the lowest cost single-coverage plan offering minimum value.

This data is maintained by employers, and is captured in events like new-hire procedures and open enrollment. Cigna can confirm the lowest cost single coverage medical plan from our offering. Our clients can also download eligibility reports from their secure client website. However, this data will only capture enrollees of the plans – not all of the employees whom were actually offered coverage.

Self-insured plans of any size have to report annual data that includes: name, social security number and coverage information on every individual covered during the calendar year. This includes reporting on dependents. While small employers are not required to offer minimum essential coverage to their employees, if they self-insure any such coverage they must report on the covered individuals annually to the IRS.

Coverage data is maintained by Cigna, and can be found on our clients’ secure client websites.

Cigna will report annually on all covered individuals with insured medical coverage. Per the regulations, we will also reach out to all responsible individuals who can provide missing social security numbers (SSNs) for themselves and/or their dependents.

Clients can track the data Cigna will use to generate outreach for missing SSNs and reporting to the IRS via our secure client websites.

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:

What various SSN data means in these reports
SSN Rule Example What it means
Blank field OR All zeros _ _ _-_ _-_ _ _ _
000-00-0000
A missing SSN
Outreach is needed for a valid SSN
First three digits cannot be 000 000-12-1234
An invalid SSN
Outreach is needed for a valid SSN
First three digits cannot be 900-999 or 666 900-12-1234
666-12-1234
An invalid SSN
Outreach is needed for a valid SSN
Cannot have zeros in the middle two or last four digits 123-00-1234
123-12-0000
An invalid SSN
Outreach is needed for a valid SSN
A range of numbers following a 3-2-4 digit sequence 123-45-6789 A valid SSN
Cigna has required data
IRS Requirements and Sample Communications

The Internal Revenue Service (IRS) has developed instructions and forms to give employers and insurers direction on how they'll report information required with both Large Employer and Minimum Essential Coverage reporting. Large employers who self-insure their group medical plans will use the same forms to complete both requirements.

Final Instructions for employers to file Final Form 1094-C Form 1094-C (a transmittal/cover sheet) to the IRS only, and Final Form 1095-C to both the IRS and named individuals. If its plan is insured, the employer will only complete Parts I and II of Form 1095-C.

The following are samples of the cover letters Cigna will include with 1095-B mailings to customers of insured health plans.

View Cigna's sample cover letter for 1095s

View Cigna Global Health Benefits’ sample cover letter for 1095s

View Cigna's sample cover letter for corrected 1095s

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.

View a sample awareness message

View sample enrollment presentation slide

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

View talking points for benefits professionals of Cigna's insured clients

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 Employer Administrative Responsibilities page as well as our Reporting Requirements fact sheet.

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