Important information about Internal Revenue Service reporting requirements for US citizens/nationals and non-US nationals

Background information

Issued: November 2017

On 31st October 2013 the US Department of Health and Human Services issued a guidance which stated that group health plan cover provided through an insurer regulated by a foreign government will be recognized as minimum essential coverage (MEC) for:

  • A month with respect to an individual who, in that month, is physically absent from the United States for at least one day of the month.

  • An individual who is physically present in the United States for an entire month if the coverage provides health benefits within the United States while the individual is on expatriate status.


To adhere with this guidance and to ensure that your plans continue to meet MEC, your health insurance provider must comply with certain reporting requirements.  Further information on these reporting requirements and what you (the policyholder) must do are provided below.

Frequently Asked Questions

1. What are the reporting requirements for US citizens/nationals who are based outside the US during the 2017 tax year?

Your health insurance provider must:

  • Issue a copy of Form 1095-B to US citizens/nationals by the 31st March 2018.
  • File Form 1094-B (along with copies of the Forms 1095-B) with the Internal Revenue Service (IRS) by the 2nd of April 2018.


2. What are the reporting requirements for non-US nationals who are based inside the US whilst on expatriate status during the 2017 tax year:

Your health insurance provider must:

  • Issue a copy of the Form 1095-B to non-US nationals by the 31st March 2018.
  • File Form 1094-B (along with copies of the Forms 1095-B) with the IRS by the 2nd of April 2018.


3. What are the reporting requirements for policyholders with dependants who are either ‘US citizens/nationals who are based outside the US during the 2017 tax year’ / ‘Non-US nationals who are based inside the US whilst on expatriate status during the 2017 tax year’?

Your health insurance provider must:

  • Issue a copy of Form 1095-B to dependants via the policyholder by the 31st March 2018.
  • File Form 1094-B (along with copies of the Forms 1095-B) with the IRS by the 2nd of April 2018.


4. What is the purpose of Form 1095-B?

Form 1095-B is used to report certain information about individuals, e.g. the minimum essential cover (MEC) held during a calendar year, to the IRS (via electronic filing) and to the individual (via post).


5. Who must file the Form 1095-B with the IRS?


The health insurance provider is responsible for collecting the required information, completing form 1095-B and submitting it to the IRS.


6. Who will receive Form 1095-B?

The policyholder who falls within the scope of the reporting requirements will receive the Form 1095-B. In some instances, where a dependant on the policy falls within the scope of the reporting requirements but the policyholder does not, the policyholder will receive the Form 1095-B on the dependants' behalf.

In this event it is the responsibility of the policyholder to furnish this form to the dependant.


7. When and how will I receive a copy of the form 1095-B from my health insurance provider?

Your health insurance provider will post the Form 1095-B to the policyholder by the 31st March 2018 using standard international post.



8. What information is shown on Form 1095-B and filed with the IRS?

The following information will be filed with the IRS for those who meet the reporting requirements outlined in questions 1, 2 and 3.

  • Policyholder’s name
  • Policyholder’s address
  • Social Security Number (SSN) or Taxpayer Identification Number (TIN)
  • Date of birth (If SSN not available)
  • Covered individual’s name (i.e. policyholder or dependant name where relevant)
  • Covered individual’s Social Security Number (SSN) or Taxpayer Identification Number (TIN)
  • Covered individual’s date of birth
  • Covered individual’s number of months in the 2017 tax year under a policy recognised as MEC Note. Please note that the term ’covered individual’ may refer to the policyholder and/or any dependant(s) including their spouse.



9. What information do I need to provide to my health insurance provider?

The policyholder is required to provide the following information:

  • Name
  • Policy number
  • Company name
  • Policyholder correspondence address
  • Social Security Number (SSN) or Taxpayer Identification Number (TIN)
  • Date of birth
  • Dependant(s) Name (where applicable)
  • Dependant(s) Social Security Number (SSN) or Taxpayer Identification Number (TIN)
  • Dependant(s) date of birth


 
10. What is a Taxpayer Identification Number (TIN)?

A Taxpayer Identification Number (TIN) is an identification number used by the IRS in the administration of tax laws. It is issued either by the Social Security Administration (SSA) or by the IRS.

The following are all valid Taxpayer Identification Numbers:

  • Social Security Number "SSN" - 9 digit number issued by the Social Security Administration (SSA)
  • Employer Identification Number "EIN" (issued by the IRS)
  • Individual Taxpayer Identification Number "ITIN" (issued by the IRS)
  • Taxpayer Identification Number for Pending U.S. Adoptions "ATIN" (issued by the IRS)
  • Preparer Taxpayer Identification Number "PTIN" (issued by the IRS)



11. Where do I provide the required information?

The required information can be provided by clicking here and completing a short questionnaire.



12. What happens if I do not complete the questionnaire?

Your health insurance provider requires you to confirm details which will be used to complete  Form 1095-B. Policyholders who do not provide the required information may be liable for the individual shared responsibility payment if your health insurance provider is unable to inform the IRS that the health insurance cover held met MEC requirements.



13. Where can I find more information:

Further information is available from www.irs.gov/Affordable-Care-Act/Questions-and-Answers-about-Reporting-Social-Security-Numbers-to-Your-Health-Insurance-Company.