Annual health plan reporting for employers

A simplified guide to what’s due and when.

Managing annual reporting requirements is easier when you know what to expect. Whether you are fully insured, self-funded or level-funded, there are several annual reporting requirements tied to your health coverage. These reports help maintain compliance with federal regulations and ensure accurate data is submitted to the IRS, CMS and the Department of Labor. 

Throughout the year, Blue Cross and Blue Shield of Kansas (BCBSKS) provides reminders and supporting information to help groups stay compliant. Below is an overview of each reporting requirement, when it occurs and the actions needed from your group.

Employers that are a part of an Association Health Plan may have reporting requirements handled differently than individual employers, as outlined below.

Medical Loss Ratio (MLR) Reporting

MLR is a key financial metric used in the health insurance industry to assess how much of the premium revenue is spent on medical care and health care services, as opposed to administrative costs. Calculating MLR is a requirement for health insurance companies in the U.S. and must be submitted annually.

Applies to: Employers with a fully insured, level funded or minimum premium health plan. Employers with an Administrative Services Only (ASO) plan, a dental only plan and all COBRA groups do not need to submit their employee count.

Communication: An email or letter, if no email address is available, is sent in January, with a reminder sent two weeks later, requesting employers to provide their employee count from the prior year to BCBSKS. 

Requested action: Submit your group’s total employee count to BCBSKS through the Medical Loss Ratio portal for the prior year.

Due date: End of February

MLR Mid-year info

In July, a letter will be sent to groups with 45-55 employees to confirm their group size in BlueAccess.

1095 Reporting

BCBSKS is required to provide an electronic copy of 1095-B forms to insured members (excluding members of a self-insured plan). These employees can access their 1095-B form through their personal BlueAccess account. Self-insured employers are responsible for providing 1095-C forms to their covered employees. 

Applies to: Employers with any plan type (fully insured, ASO, level funded, etc.)

Communication: An email or letter, if no email address is available, is sent in February, informing employers that their 1095-B report is available in BlueAccess and what action, if any, they need to take.

Requested action: Dependent on your company size and plan type, you may need to submit specific forms to the IRS and to your employees. 

Due date: February 28 if filing by mail or March 31 if filing electronically with the IRS. Employers providing 1095-C forms to their full-time employees must distribute them by March 2.

RxDC Pharmacy Report (RxDC)

The Consolidated Appropriations Act (CAA) of 2021 requires group health plans or health insurers, like BCBSKS, to report data on health plan premiums and various health care spending categories, along with certain prescription drug information, to the federal government. 

Applies to: Employers with any plan type

Communication: An email or letter, with an email reminder two weeks prior to the portal closing, is sent informing employers of the requirement to submit specific premium and pharmacy-related data for the annual RxDC.

Requested action: Submit your group’s premium and pharmacy-related information to BCBSKS through the Premium Reporting portal, if you want BCBSKS to submit data on your behalf.

Due date: April 30

You can find more information on the CAA page on BCBSKS’ website under Employer Groups > Pharmacy reporting procedures. Note: If a group changes from ASO to fully insured or fully insured to ASO, they will need to fill out two forms.

Patient-Centered Outcomes Research Institute (PCORI)

The PCORI fee is required as part of the Patient Protection and Affordable Care Act (PPACA) and is designed to support PCORI.

Applies to: Employers with an ASO or level funded health plan. BCBSKS pays the fee for fully insured and minimum premium groups.

Communication: An email or letter is sent in February notifying Plan Administrators that their PCORI reports are available in BlueAccess. Reports are posted under the group’s MPN and include the information needed to help employers complete their IRS filing.

Requested action: Employers need to submit payment to the IRS based on the average number of people covered by their plan from the prior year.

Due date: July 31

Part D Group Creditable Coverage

When a policy is considered to have creditable coverage, that means the coverage is expected to pay on average as much as, or more than, the standard Medicare prescription drug coverage. Employers that provide prescription drug coverage to individuals who are eligible for Medicare Part D must inform these individuals and the Centers for Medicare and Medicaid Services (CMS) whether their prescription drug coverage is creditable.

Applies to: Employers with any plan type that offer prescription drug coverage

Communication: An email is sent in September to inform employers that creditable coverage letters are now available in BlueAccess. 

Requested action: Employers need to inform all Medicare-eligible employees in writing if their prescription drug coverage is creditable or non-creditable, as outlined in the letter available in BlueAccess. Employers must also complete the Online Disclosure to CMS Form, regardless of creditable status.

Due date: October 15 to employees and within 60 days of the start of your plan year to CMS

For information about creditable coverage and disclosure requirements, visit the Centers for Medicare and Medicaid Services.

Gag Clause

The Gag Clause Attestation is an annual federal requirement confirming that groups and insurers offering group coverage do not engage in contracts that restrict access to provider-specific cost, quality or claims data. BCBSKS attests on behalf of eligible groups that submit their information by the required deadline.

Applies to: Employers with any plan type

Communication: An email or letter, with an email reminder two weeks prior to the portal closing, is sent letting employers know whether BCBSKS will attest on their behalf or if action is needed.

Requested action: Fully insured and minimum premium groups may request to be excluded if they prefer to submit their own attestation. Self-insured and level-funded groups can opt in for BCBSKS to attest on their behalf.

Due date: Mid-November for self-funded groups opting in or fully insured groups opting out for BCBSKS to report on their behalf, and December 31 for any employer submitting their own attestation to CMS.

You can find more information on the CAA page on BCBSKS’ website under Employer Groups > Gag Clause Attestation.

If you have questions about any of these requirements, reach out to your BCBSKS sales representative. While they may not be able to provide legal advice or tax guidance, they can help clarify what applies to you and point you toward the appropriate resources to keep your group compliant.

All timelines provided are estimates and are subject to change based on project scope, resource availability and unforeseen circumstances.