Massachusetts requires its residents (over the age of 18) to carry minimum creditable coverage (MCC) or pay a penalty. It is a similar requirement to the now-repealed ACA Individual Mandate; however, a MCC determination involves a more in-depth review. Employers providing MCC to Massachusetts residents must distribute Form MA 1099-HC to them and submit reporting electronically to the Department of Revenue (DOR) by January 31, after the end of the medical plan year. However, employers are not required to offer MCC, and there's no penalty if the coverage the employer offers does not meet the MCC standard. If an employer is unsure if its plan is considered MCC, the employer can request the Health Connector to make the determination.
For fully insured plans issued in MA, the insurers generally administer these requirements on behalf of the employers. Employers with self-insured (including level-funded) plans and non-Massachusetts employers are required to complete the distribution and filing requirements themselves. Note that Form MA 1099-HC only needs to be sent to primary enrollees and does not also need to be sent to dependents. Failure to distribute and file Form MA 1099-HC may result in a penalty of $50 per individual, up to a maximum of $50,000.
Covered employers: All employers with at least one Massachusetts-resident employee must comply with the Form MA 1099-HC requirement. Employers can obtain draft copies of Form 1099-HC on the DOR website.
Due date: January 31, following the end of the medical plan year.
Information reported on MA Form 1099-HC: A Form 1099-HC indicates the months that the employees and any dependents were enrolled in MCC in the reporting year.
Filing method: Employers must submit Form MA 1099-HC information to DOR electronically in properly formatted XML through MassTaxConnect. For additional information about how to file Form MA 1099-HC information, please refer to the state site: Submitting Information to DOR.
The Form MA 1099-HC needs to be sent only to the primary subscriber.
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Health Connector - HDHPs and MCC Requirements »