As you probably know, Massachusetts has minimum creditable coverage (MCC) standards that health plans must meet so that residents can satisfy the mandate that they have health insurance. If the medical benefits that administrative service contract accounts (ASC) purchase through Blue Cross Blue Shield of Massachusetts satisfy MCC requirements, we will issue 1099-HC statements to subscribers enrolled in the plan indicating coverage was in compliance with MCC requirements.

If the medical benefits ASC accounts purchase through Blue Cross Blue Shield of Massachusetts do not satisfy MCC requirements because they opt to exclude certain benefits, but offer additional coverage for these benefits through another carrier, the combined benefits package may meet MCC standards.

ASC accounts should consult with their own advisor, such as legal counsel, who may be able to confirm that the health plan is MCC-compliant if the combined benefits package meets MCC requirements. If an ASC account believes its total benefit offering meets MCC, the account may provide us with a Plan Sponsor Attestation form attesting that their benefits meet MCC. Note that to meet MCC standards, subscribers cannot have the option of opting out of the additional benefits. Completed Plan Sponsor Attestation forms must be returned to Blue Cross Blue Shield of Massachusetts by November 1, 2009.

Blue Cross Blue Shield of Massachusetts will provide 1099-HC services on behalf of the plan sponsor contingent upon receipt of the authorized Plan Sponsor Attestation.

If the medical benefits ASC accounts purchase through Blue Cross Blue Shield of Massachusetts do not satisfy MCC requirements because they opt to exclude certain benefits and additional coverage is not provided through another carrier, Blue Cross Blue Shield of Massachusetts will issue a 1099-HC statement to subscribers enrolled in the plan indicating coverage did not meet MCC requirements and instructing the subscriber to contact the employer.

If ASC accounts do not want Blue Cross Blue Shield of Massachusetts to issue a 1099-HC statement to employees, they should notify Blue Cross Blue Shield of Massachusetts no later than November 1, 2009.

Letters will be mailed by the end of September to all ASC accounts that do not meet MCC standards.

If you have any questions, please contact your account executive.