IRS FORM 1095-A Talking Points

IRS FORM 1095-A
TALKING POINTS
January 20, 2015
January 20, 2015 - Covered California updated:
 IRS Form 1095-A important notes
 ROLES AND RESPONSIBILITIES FOR THE IRS FORM 1095-A & IRS FORM 8962 under
Covered California and Consumers
BACKGROUND
Effective January 1, 2014, under the Affordable Care Act (ACA), most individuals are required to
enroll in health care coverage that meet the minimum essential coverage standards outlined in
the ACA or else they may have to pay a penalty when they file their federal income taxes.
Individuals can apply for a health coverage exemption as one of the three choices they have
under the mandate: 1) coverage 2) exemption and 3) penalty. Individuals filing their federal
income taxes must be able to prove they (the taxpayers and their dependents) were enrolled in
qualifying health care coverage. Therefore, the Internal Revenue Service (IRS) created forms for
taxpayers to use when filing their federal income taxes. These forms will be covered in the next
few sections of this document.
The ACA also requires health care exchanges (marketplaces) like Covered California to report
consumers’ health care coverage information to the IRS to ensure individuals are meeting
health care coverage requirements. In addition, Covered California is required to mail an IRS
Form 1095-A (see Exhibit A) to its enrollees at the beginning of each year that details the
amount of the Advanced Premium Tax Credit (APTC) received, if applicable.
There are three types of IRS Forms 1095, as listed below. No federal requirement has been
mandated for Medicaid (Medi-Cal) programs administrators, health insurance carriers, and
employers to provide IRS Forms 1095 to their consumers for the 2014 calendar year.



IRS Form 1095-A: provided by health care exchanges (marketplaces – Covered California
in California)
IRS Form 1095-B: will be provided by Medicaid programs (Medi-Cal in California) but
they are not required to provide to consumers for the 2014 calendar year
IRS Form 1095-C: will be provided by health insurance carriers or employers with
sponsored health plans but they are not required to provide to consumers for the 2014
calendar year
IRS FORM 1095-A

IRS Form 1095-A (also called the “Health Insurance Marketplace Statement”) will be
used by all Health Care Exchanges.
Page 1 of 22
IRS FORM 1095-A Talking Points
V.2
IRS FORM 1095-A
TALKING POINTS
January 20, 2015





IRS Form 1095-A details Covered California consumers’ 2014 coverage and contains
information that is needed to help consumers validate the amount of APTC they may
have received or, if they have not received APTC, to see if they might be eligible to
receive a lump sum Premium Tax Credit (PTC) when they file their federal income taxes.
The PTC will reimburse consumers for some of the premiums they’ve paid for coverage
in 2014. This eligibility evaluation is done by the consumer or tax preparer on IRS Form
8962 (Premium Tax Credit (PTC)).
Covered California mails the Form 1095-A to both the IRS and the individual consumer
listed as the primary tax filer on the Covered California application. The form will be
prepopulated with information reported by the tax filer when they applied for health
insurance through Covered California (with any reported changes).
Consumers will use the information listed on the Form 1095-A in order to complete IRS
Form 8962. Consumers must complete IRS Form 8962 (see Exhibit B) and file it with their
federal income tax return if they want to claim the Premium Tax Credit or if they
received APTC for at least one month in 2014 (whether or not they are required to file a
tax return).
If consumers or their family members enrolled in more than one health insurance plan,
also known as a Qualified Health Plan (QHP), through Covered California, they will
receive a different Form 1095-A for each health insurance plan, but will only need to
complete one IRS Form 8962.
IMPORTANT NOTE:
o Covered California issued an IRS Form 1095-A to consumers who are enrolled in
a Minimum Coverage Plan (Catastrophic plan). However, these individuals do not
have to use this Form 1095-A when filing their federal income taxes.
o Covered California will not issue an IRS Form 1095-A to consumers who
purchased health plans through Covered California’s Small Business Health
Options Program (SHOP).
o Department of Health Care Services (DHCS) will not issue an IRS Form 1095-B to
consumers who are enrolled in the Medi-Cal Program for the 2014 calendar year.
o Consumers who were enrolled in either a Minimum Coverage Plan or in Medi-Cal
for the whole 2014 calendar year will not need to complete the IRS Form 8962
since they were not eligible for premium tax credits (premium assistance).
o Consumers who were enrolled in both a health insurance plan through Covered
California and in Medi-Cal will only receive an IRS Form 1095-A that reflects the
Covered California coverage.
IRS Form 8962
Page 2 of 22
IRS FORM 1095-A Talking Points
V.2
IRS FORM 1095-A
TALKING POINTS
January 20, 2015





IRS Form 8962 is the federal tax form that requires individuals to prove that they (the
taxpayers and their dependents) were enrolled in health care coverage when filing their
federal income tax return.
IRS Form 8962 will be used to calculate the consumer’s eligibility for, and the amount of,
Premium Tax Credit (PTC) they are eligible to receive to help make their health
insurance coverage more affordable. The consumer’s information on the IRS Form 8962
is compared to the amount of APTC the consumer may have already received in 2014. If
they have received too much, they may have to pay back some or all of the tax credits
that have been paid for their health care coverage premiums. If they have received too
little in APTC, they may be eligible to be paid the extra amount they should have
received in the form of a tax refund or PTC.
If consumers chose to be considered for affordability programs such as APTC when they
applied for coverage through Covered California, Covered California estimated APTC
eligibility at that time by using information about their household and their estimated
2014 yearly Modified Adjusted Gross Income (MAGI) that they provided on their
application. IRS Form 8962 will help them determine if they have received too much or
too little in APTC, based on what they truly earned and are reporting on their taxes for
2014
For those consumer households that did not receive APTC in 2014, the IRS Form 8962
will help them see if they should have received tax credits for any month in 2014, based
on their information when they file their federal income tax return. If they are eligible
for tax credits based on the information in Form 8962, they may be eligible to receive
the amount of tax credits they should have received throughout 2014 in the form of a
tax refund (PTC).
Consumers filing their federal income taxes will need to use their IRS Form 1095-A to
prepare the IRS Form 8962. The IRS provides specific instructions on how to understand
the form and the information needed to complete it. Visit: http://www.irs.gov/pub/irspdf/f8962.pdf or got to www.irs.gov and type in “8962” or “Premium Tax Credit (PTC)”
in the search bar.
ROLES AND RESPONSIBILITIES FOR THE IRS FORM 1095-A & IRS FORM 8962
Covered California:

Generates and mails the IRS Form 1095-A with a consumer notice (see Exhibit C –
English draft) to applicable consumers enrolled in Covered California and to the IRS.
Consumer notices will be generated in the following languages: English, Spanish,
Chinese, Korean, and Vietnamese. For assistance in other languages consumers should
refer to page 6 of the notice.
Page 3 of 22
IRS FORM 1095-A Talking Points
V.2
IRS FORM 1095-A
TALKING POINTS
January 20, 2015


Makes changes to the IRS Form 1095-A as reported and resends to consumers and the
IRS.
Will not send IRS Form 1095-A to:
o Consumers who purchased health plans through Covered California’s SHOP, and
o Consumers enrolled in Medi-Cal, including individuals enrolled in Medi-Cal who
are part of a Mixed Household. Read more information about the Mixed
Household status starting on page 6 of this document.
Consumers:








Review the IRS Form 1095-A to ensure all their information is correct.
Report to Covered California if there are changes or discrepancies in the APTC amounts
that need corrections. Consumers can compare the APTC amounts on the IRS Form
1095-A with their health insurance plan invoice.
Discrepancies with the health insurance plan premium amounts or APTC amounts
should be reported using the Covered California Consumer 1095-A Dispute Form (See
Exhibit D draft).
Discrepancies with Name, Date of Birth, Social Security Number, and Address can be
reported to the Covered California Service Center or the local county social services
office for Mixed Households (households with consumers enrolled in both Medi-Cal and
Covered California). Discrepancies with APTC and any other information on the form
that needs to be reconciled can only be accomplished via the 1095-A Dispute Form.
Consumers that have not received an IRS 1095-A Form during the first week of February
should contact the Covered California Service Center or log into your CoveredCA.com
account and go to your secured mailbox to see if there is a 1095-A available for you to
download.
Use the IRS Form(s) 1095-A to file their federal income taxes via the IRS Form 8962.
Use the IRS Form 8962 to calculate the actual premium tax credit as determined by their
actual tax household size and income for the 2014 calendar year.
Can apply for a health coverage exemption by filling out one of the exemption forms
available at healthcare.gov or by filing IRS Form 8965, Health Coverage Exemptions, to claim a
coverage exemption on their federal income tax filing.
Certified Enrollment Counselors (CECs), Plan-Based Enrollers (PBEs), and Certified Insurance
Agents (CIAs):


Educate consumers about the IRS Form 1095-A purpose and how to read it.
Help consumers notify Covered California when there are discrepancies on the IRS Form
1095-A. Discrepancies with names, dates of birth, social security numbers, and
addresses can be reported to any Covered California Service Center or the local county
Page 4 of 22
IRS FORM 1095-A Talking Points
V.2
IRS FORM 1095-A
TALKING POINTS
January 20, 2015



social services office for Mixed Households (households with consumers enrolled in
both Medi-Cal and Covered California). Any other discrepancies that need to be
reconciled, including plan and APTC information, can only be accomplished via the 1095A Dispute Form.
Know the tax penalty rules and how they work. Reference the FAQ for more
information.
Do NOT provide or give tax advice to consumers on how to file their federal income
taxes.
Do NOT fill out federal tax forms.
IRS FORM 1095-A RECONCILIATION
This section covers how you can help consumers report discrepancies that need to be changed
to Covered California. Consumers, Certified Insurance Agents, Certified Enrollment Counselors,
and Plan-Based Enrollers may contact any Covered California Service Center to report only the
following discrepancies on the IRS 1095-A Form:




Name
Date of Birth
Social Security Number (SSN)
Home or Mailing Address
Consumers should use the Covered California Consumer 1095-A Dispute Form (Exhibit D) to
report discrepancies on their IRS 1095-A Form for these types of coverage information:





Incorrect APTC amount listed
Incorrect months of coverage listed (for example: the Form 1095-A shows that you were
enrolled for certain months when you were not)
Months of coverage not shown
Incorrect covered individual start date or end date
Incorrect policy start date or end date
The final version of the Covered California 1095-A Dispute Form will be posted on our website
towards the end of January 2015.
REVISED IRS FORM 1095-As
Page 5 of 22
IRS FORM 1095-A Talking Points
V.2
IRS FORM 1095-A
TALKING POINTS
January 20, 2015
•
•
A revised or corrected Form 1095-A will have the “Corrected” box at the top checked to
indicate that the IRS Form 1095-A was corrected from the original form.
Consumers may need to file an “amended” federal income tax return if:
o Consumers filed their federal income taxes before they received their IRS Form
1095-A from Covered California.
o Consumers did not use the information from the latest corrected IRS Form 1095A to file their federal income taxes if changes were made to the original IRS Form
1095-A.
•
For more information, consumers can visit www.irs.gov and enter the keywords
“amended return” in the search bar.
MULTIPLE IRS FORMS 1095-A
Reasons why consumers may receive more than one IRS Form 1095-A for one calendar year:
•
Consumer households that contained individuals that were enrolled in more than one
health insurance plan during the 2014 calendar year will receive multiple IRS Forms
1095-A (one for each health insurance plan).
o For example, if they were enrolled in Health Net from January 2014 through June
2014 and then enrolled in Kaiser Permanente July 2014 through December 2014,
the primary tax filer in the consumer household will receive two IRS Forms 1095A. One for Health Net and another for Kaiser Permanente.
•
Consumers changed their health plan level, also known as “metal tier level”, during the
2014 calendar year.
o For example, consumers changed their health plan level or “metal tier” from
Silver to Gold, but did not change their health insurance carrier.
•
Consumer households that contained individuals who were not all enrolled in the same
health insurance carrier plan.
o For example, Mom, who is a member of a Federally Recognized Indian Tribe, was
enrolled in an Indian Tribe plan that has special benefits available to only tribe
members. Dad and the children were enrolled in Covered California Western
Health Advantage.
Page 6 of 22
IRS FORM 1095-A Talking Points
V.2
IRS FORM 1095-A
TALKING POINTS
January 20, 2015
•
Households with more than four members may receive multiple pages of the form. Part
II of the form will list the other household members, while the other sections of the
form will contain the same information.
MIXED HOUSEHOLDS (COVERED CALIFORNIA & MEDI-CAL)
Households with at least one member enrolled in Covered California, and at least one member
enrolled in Medi-Cal, are referred to as Mixed Households. DHCS will not be sending the IRS
Form 1095-B to consumers enrolled in Medi-Cal during the 2014 calendar year. Therefore,
Mixed Household consumers will use the IRS Form 1095-A issued by Covered California to
report APTC received for the Covered California consumer(s) and provide attestation on their
federal tax filing stating that the Medi-Cal consumer had health coverage for the 2014 calendar
year.
In an effort to protect the Medi-Cal consumer, Covered California representatives must refer
the Medi-Cal consumer to the local county social service offices to make any personal
information (name, date of birth, social security number, address) changes needed to a
Mixed Household’s case.
Discrepancies to the health insurance plan premium amounts or APTC amounts for Mixed
Households should be reported to Covered California Service Center or via the Covered
California 1095-A Dispute Form.
RESOURCES
•
IRS Instruction Manual: http://www.irs.gov/pub/irs-pdf/p5187.pdf
o IRS Form 1095-A, Health Insurance Marketplace Statement:
http://www.irs.gov/pub/irs-pdf/f1095a.pdf
o IRS Form 8962, Premium Tax Credit (PTC): http://www.irs.gov/pub/irspdf/f8962.pdf
•
Federal Health Care Exchange Marketplace: https://www.healthcare.gov/feesexemptions/fees-exemptions-overview/
Covered California Reconciliation Information:
http://hbex.coveredca.com/stakeholders/planmanagement/PDFs/APTC%20Letter%20(v2)%20DRAFT.pdf
Covered CA Tax Credit FAQ’s: http://www.coveredca.com/faqs/Tax-Credits/
Volunteer Income Tax Assistance: Free tax assistance for consumers who generally has
an annual income of $53,000 or less, persons with disabilities, and the elderly and
•
•
•
Page 7 of 22
IRS FORM 1095-A Talking Points
V.2
IRS FORM 1095-A
TALKING POINTS
January 20, 2015
limited English speaking taxpayers. To find help, consumers can call 1-800-906-9887 or
check online at www.irs.treasury.gov/freetaxprep/.
COVERED CALIFORNIA SERVICE CENTERS
Consumers
Covered California Consumer Service Center
1-800-300-1506
Monday through Friday, 8:00 AM – 8:00 PM
Saturday and Sunday, 8:00 AM – 6:00 PM
Certified Insurance Agents
Covered California’s Agent Service Center
1-877-453-9198
E-mail: Agents@covered.ca.gov
Monday thru Friday, 8:00 AM to 8:00 PM
Saturdays, 8:00 AM to 6:00 PM
Open some Sundays during Open Enrollment. Check the
January Agent Service Center calendar for availability.
Certified Enrollment Counselors &
Plan-Based Enrollers
CEC/PBE Help Line
1-855-324-3147
Monday through Friday, 8:00 AM – 8:00 PM
Saturday and Sunday, 8:00 AM – 6:00 PM
Page 8 of 22
IRS FORM 1095-A Talking Points
V.2
IRS FORM 1095-A
Exhibit A
January 9, 2015
Page 9 of 22
IRS FORM 1095-A Talking Points
V.2
IRS FORM 8962
Exhibit B
January 9, 2015
Page 10 of 22
IRS FORM 1095-A Talking Points
V.2
DRAFT CONSUMER 1095
NOTICE ENGLISH: 7 Pages
Exhibit C
January 9, 2015
Page 11 of 22
IRS FORM 1095-A Talking Points
V.2
DRAFT CONSUMER 1095
NOTICE ENGLISH: 7 Pages
Exhibit C
January 9, 2015
Page 12 of 22
IRS FORM 1095-A Talking Points
V.2
DRAFT CONSUMER 1095
NOTICE ENGLISH: 7 Pages
Exhibit C
January 9, 2015
Page 13 of 22
IRS FORM 1095-A Talking Points
V.2
DRAFT CONSUMER 1095
NOTICE ENGLISH: 7 Pages
Exhibit C
January 9, 2015
Page 14 of 22
IRS FORM 1095-A Talking Points
V.2
DRAFT CONSUMER 1095
NOTICE ENGLISH: 7 Pages
Exhibit C
January 9, 2015
Page 15 of 22
IRS FORM 1095-A Talking Points
V.2
DRAFT CONSUMER 1095
NOTICE ENGLISH: 7 Pages
Exhibit C
January 9, 2015
Page 16 of 22
IRS FORM 1095-A Talking Points
V.2
DRAFT CONSUMER 1095
NOTICE ENGLISH: 7 Pages
Exhibit C
January 9, 2015
Page 17 of 22
IRS FORM 1095-A Talking Points
V.2
DRAFT CONSUMER 1095
DISPUTE FORM: 5 Pages
Exhibit D
January 9, 2015
Page 18 of 22
IRS FORM 1095-A Talking Points
V.2
DRAFT CONSUMER 1095
DISPUTE FORM: 5 Pages
Exhibit D
January 9, 2015
Page 19 of 22
IRS FORM 1095-A Talking Points
V.2
DRAFT CONSUMER 1095
DISPUTE FORM: 5 Pages
Exhibit D
January 9, 2015
Page 20 of 22
IRS FORM 1095-A Talking Points
V.2
DRAFT CONSUMER 1095
DISPUTE FORM: 5 Pages
Exhibit D
January 9, 2015
Page 21 of 22
IRS FORM 1095-A Talking Points
V.2
DRAFT CONSUMER 1095
DISPUTE FORM: 5 Pages
Exhibit D
January 9, 2015
Page 22 of 22
IRS FORM 1095-A Talking Points
V.2