Massachusetts: Health Plan Reporting Rules for Employers

IRS Releases Drafts of 2019 ACA Reporting Forms and Instructions
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U.S. Department of Labor Releases Advance Copies Of Form 5500 Annual Return/Report for 2019
November 18, 2019

The Commonwealth of Massachusetts imposes two different health coverage reporting requirements on employers.

The first is called HIRD and it applies to any employer with six or more workers in Massachusetts – even if the employer does not offer any health coverage. It is due December 15, 2019.

The second requirement is Form MA 1099-HC and it only applies to employers that offer health coverage that meets certain minimum standards. It will be due January 31, 2020.

What You Need to Know About HIRD

HIRD stands for the Health Insurance Responsibility Disclosure and refers to an online “form” that collects employer information. Employers simply report whether or not they offer group health coverage and, if so, provide basic plan information. No individual employee data is requested.

It’s required! All employers with six or more workers in Massachusetts in 2019 must complete the HIRD by December 15, 2019. It’s a simple online process. Use the MassTaxConnect (MTC) website, log into the employer’s MTC withholding account, and select the “file health insurance responsibility disclosure” link.

The Commonwealth provides FAQs in simple language that cover all the questions that typical employers have about the HIRD requirement.

What You Need to Know About MA 1099-HC

The Commonwealth requires all residents age 18 or older to maintain health coverage that meets specific standards or they will be subject to a state tax penalty. Plans that meet the standards are called minimum creditable coverage or MCC. MCC may be provided through a governmental program, such as Medicare, or through an individual medical insurance policy or an employer’s insured or self-funded group medical plan.

Insurers, employers, or other entities that provide MCC to Massachusetts residents must distribute Form MA-1099-HC Individual Mandated Massachusetts Health Care Coverage to them by January 31 following the year of coverage. For instance, for coverage that applied for any month in 2019, the form is due no later than January 31, 2020. The form discloses that the plan qualified as MCC, identifies the enrollee (and dependents, if any) and indicates the months of coverage. The information also is reported to the Commonwealth’s Department of Revenue (DOR).

If the employer’s coverage was provided through a group insurance policy issued in Massachusetts, the insurer will prepare and distribute the forms to enrollees and file the report with the DOR.

If the employer’s coverage was provided through a group policy issued in another state, or the employer’s plan was self-funded, the employer is responsible for ensuring the MCC disclosure requirement is met. Most out-of-state insurers, and third-party administrators (TPAs), will provide this reporting service to employers upon request.

In summary, employers with six or more Massachusetts workers at any time in 2019 will need to complete the HIRD by December 15, 2019. Also, employers that provided MCC to any Massachusetts residents in 2019 should confirm that their insurance carrier or TPA will prepare and distribute Form MA-1099-HC to the enrollees by January 31, 2020 and file the required report with the DOR.

Kathy Berger

Kathy Berger is ThinkHR’s principal benefits consultant. She is a Certified Employee Benefits Specialist (CEBS) with over 25 years of experience working with brokers and employers. Kathy uses her extensive knowledge of ERISA, HIPAA, the ACA, and other benefits laws and regulations to assist our clients with practical information in clear language.

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