Posting Date: November 26, 2018
Action required: Yes
What: All employers with the MERS Health Care Savings Program must complete and submit 1094-B and 1095-B forms to comply with IRS regulations relating to the Affordable Care Act.
Key Date(s): See below
Impacted audiences: All MERS Health Care Savings Program employers with terminated participants who are using their HCSP account for eligible medical-related purchases
MERS' legal counsel has reviewed the Affordable Care Act (ACA) guidance and determined that the MERS Health Care Savings Program HCSP) may qualify as minimum essential coverage (MEC).
For the purposes of HCSP, MEC applies to individuals who have access to their HCSP account for reimbursements of medical expenses (generally, this means terminated or retired participants with a balance). Employers who sponsor such programs are required to file a 1094-B Transmittal of Health Coverage Information Returns form (one per municipality) and a copy of the completed 1095-B Health Coverage forms for each terminated employee with an HCSP account balance. Additionally, employers are required to provide the completed 1095-B form to the terminated employee. MERS will provide employers with the data needed to populate these forms in the Employer Portal in December.
If you have other programs similar to the MERS Health Care Savings Program, we recommend that you contact their other service provider(s) to ensure they are in compliance with this requirement.
January 31, 2019 – Deadline to provide a completed 1095-B form to terminated HCSP participants/beneficiaries with an account balance
February 28, 2019 (if filing by paper) or April 1, 2019 (if filing electronically) – Deadline to file completed 1094-B and 1095-B forms with the IRS
Resources available: Click to View
For more information, contact: The MERS Service Center at 800.767.MERS (6377)