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Carrier News

Employer Information Reporting: Resources for Self-Funded Small Groups by Carrier

Employers who offered a self-funded plan at any point in a calendar year are required to report certain information to the IRS and to taxpayers about individuals who were covered by Minimum Essential Coverage (MEC). This obligation to report is unique to employers–of any size–who offered self-funded plans. An employer who is also an Applicable Large Employer (i.e.: a large group subject to the ‘Employer Mandate’) uses Forms 1095-C and 1094-C. An employer who is not an Applicable Large Employer uses Forms 1095-B and 1094-B. This article is about how carriers help the latter–small employers offering self-funded plans who use the B-series forms to report about employees covered by MEC.

Read our article Employer Reporting Requirements under the ACA for technical details, access to the forms, and official guidance from the IRS.

CarrierProgram NameService and Support Provided
All Savers (UHC)Alternative FundingPrepares employee statements (1095-B) for groups with less than 50 enrolled and publishes in the employer portal. They do not distribute the forms or file with the IRS. Clients download the statements, distribute the statements themselves, prepare the employer transmittal (1094-B), and submits everything to the IRS. Groups can download a membership report from the employer portal.
BCBSBlue Balance FundedDoes not prepare forms. Groups can generate a ‘Members Listings Report’ in BAE to obtain the membership data. Note, BCBS sent errant Forms 1095-B to some members about 2018 coverage. These statements are not valid. Groups must generate their own forms in order to report to the IRS.
CignaLevel Funding, Graded Preferred, ASO, et alDoes not prepare forms. Groups and/or brokers can obtain a membership report from the employer portal. For assistance, contact 855-275-0555 or ASO_PPACA_Fees&Reporting@Cigna.com.
HumanaLevel Funded PremiumWill prepare the forms, distribute statements to employees, and file with the IRS on the employer's behalf. Groups can opt-out using this form and download a membership report from the employer portal (see instructions).
National GeneralSelf-FundedProvides a tool clients can use to generate the employee statements and employer transmittal. The platform generates the forms and emails a zip package to the client. Clients are responsible for distributing to employees and filing with the IRS. In late Jan, each client received an email with a personalized link to register for the tool. View this presentation for more info. Groups who choose not to use the tool can generate a census listing in the employer portal.
AetnaAetna Funding AdvantageWill prepare the forms, distribute statements to employees, and file with the IRS on the employer's behalf. Groups can opt-out using this form and obtain membership data via Springboard.

Humana and Aetna will prepare and file the B-series information returns as a service to employers, but be careful. Applicable Large Employers (ALEs) cannot report using the B-series forms. ALEs must opt-out of these services. The IRS requires ALEs to combine their MEC reporting with their Employer Mandate reporting using the C-series forms. A group with less than 50 employees may be an ALE if it shares common ownership or control with another group and the combined total is 50 or more.

Outsourcing Options

There are three components to outsourcing the reporting process: preparing the forms, mailing the statements to employees, and submitting everything to the IRS. Employers can do everything themselves and smaller employers probably should. The IRS does not provide a web interface that an average employer can use to upload and submit the forms. Employers who do not outsource must submit the forms via mail. The deadline for paper submission is earlier than electronic submission.

Carriers. Small groups offering self-funded plans who are eligible to report using the B-series forms should use their carrier if available. Not an option for large employers subject to the employer mandate.

Payroll Company. Not a good option for small groups, but the best option for ALEs who must combine their reporting. Payroll companies operate the central system of record for employment, eligibility, and coverage data. Groups provide their membership data to their payroll company to merge into combined report. The largest national payroll companies recognize their advantaged position and, apparently, charge high fees for this service.

Tax Professionals. Some tax advisors and CPA firms provide Form 1094/95 preparation and filing services. Others do not. Check with your professional.

Software Vendors. The industry is saturated with software companies offering form preparation and filing services. The services range from basic self-service software to end-to-end service to prepare the forms, mail statements to employees, and file with the IRS. We are aware of a few vendors:

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