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UnitedHealthcare Updates Guidance for 2023 ACA IRS Reporting

Mar 07, 2024
Category
Carrier News

Update: UnitedHealthcare has released a broker communication with specific instructions for use by UnitedHealthcare/Oxford Level Funded groups.


Based on IRS direction and in accordance with Individual Mandates, UnitedHealthcare has updated guidance for posting and notifying fully insured subscribers of annual tax forms.

Key Information | State Reporting Requirements | UnitedHealthcare's Small Group/Level Funded Approach

UnitedHealthcare plans to post 1095-B forms on member portals (e.g., myuhc.com®) for fully insured subscribers prior to the January 31, 2024, filing deadline. Resident subscribers in states with the Individual Mandate will have forms mailed unless the member has requested paperless communications.

Forms that are submitted to the Internal Revenue Service (IRS) or forms for Individual Mandate states (California, Washington, D.C., New Jersey and Rhode Island) must be submitted by March 31, 2024.

Forms that UnitedHealthcare produces and sends to IRS
(and state tax revenue where needed)
Forms that a Large FI or ASO Employer produces and sends to IRS
(and state tax revenue where needed)
  • 1094-B Transmittal of Health Coverage
  • 1095-B Health Coverage
 
  • 1094-C Transmittal of Employer-Provided Health Insurance Offer and Coverage
  • 1095-C Employer Provided Health Insurance Offer and Coverage
  • 1095-B Level Funded employers provide to members of groups with 49 or fewer FTEs

The IRS has eliminated the ability to provide transitional good faith relief for furnishing statements to individuals under Sections 6055 and 6056.

Key Information

The 1095-B form indicates the employer offered minimum essential coverage (MEC) and the months the employee was covered.

  • The 1095-B forms will be posted for members on UHC member portals before January 31, 2024, and will not be mailed to employers or employees (unless in one of the mandated states).
  • If a member needs a printed version of the 1095-B, they may call the customer service phone number on the back of their ID card.
  • Employers may not request 1095-B forms for their employees or receive a report of employees who receive a form.
  • UnitedHealthcare will submit the 1095-B forms (via a 1094-B transmittal) to the IRS and appropriate state tax revenue departments by March 31, 2024.

The 1095-C form indicates if the employer offered MEC, if the plan(s) offered was minimum value (MV) and affordable, and the months the employee was covered.

  • Applicable Large Employers (ALE) and ASOs must create and submit the 1095-C forms to their employees by January 31, 2024, and electronically submit the forms to the IRS by March 31, 2024.

Important: creating and submitting the 1095-Cs is the employer responsibility and not a UnitedHealthcare requirement. If a customer does not submit the 1095-Cs and the customer is audited, there are penalties.

State Reporting Requirements

Although for a few years individuals have no longer been subject to a federal IRS penalty if they do not comply with the ACA federal individual mandate coverage, a few states implemented their own individual mandate requirement.

  • Washington, D.C., California, New Jersey, Rhode Island, and Vermont have initiated their own Individual Mandate requirement for residents.
  • These states have both federal and state tax requirements.
  • UnitedHealthcare will submit the FI 1095-B forms to the state tax revenue department and the ALE and ASO must send the 1095-C to their members (or post online if member’s preference) and submit the 1095-C to the tax revenue department by the required date.

UnitedHealthcare's Small Group/Level Funded Approach

In support of their Level Funded/All Savers customers, UnitedHealthcare will prepare the 1095-B forms but will not send them to members. The employer must access the site to produce and send to both their subscribers and the IRS.

ASO customers may request a custom eligibility report to include month-by-month coverage that is available for a fee.

For additional information, contact your Amwins Connect Regional Sales Manager.

 

Tags
UnitedHealthcare
ACA
1095-C
Oxford

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