Blue Links for Employers

Members to supply information to comply with ACA coverage

Pursuant to the individual responsibility provision in the Affordable Care Act (ACA), beginning in 2016, individuals will be required to provide evidence of minimum essential health coverage or be subject to a penalty when they file their income tax return with the Internal Revenue Service (IRS). The IRS has created form 1095 to be used by taxpayers and entities that provide minimum essential health coverage, such as insurers and employers with self-funded health plans, to demonstrate proof of such health coverage. The ACA requires insurers and employers with self-funded health plans to send form 1095 to the IRS and the individuals covered under their health plans. This tax form requires each individual's tax ID number (usually Social Security Number). As a result, we will send out letters in late 2014 and over the course of 2015 to our fully insured subscribers requesting that they provide us with their tax ID number and the tax ID numbers of the dependents covered under their plan, if we are not able to obtain the tax ID numbers during the routine enrollment and reenrollment process.

Mailings will begin for all enrollments for benefits in 2015. We will send follow-up letters to members who have not yet responded to our request throughout 2015. We expect to continue this same process October 2015 onward.

We will distribute a 1095 form to members in January 2016. In March 2016, we will report this information to the IRS.

We will not be collecting or reporting tax IDs for members enrolled in self-funded plans. Employers should talk to their own legal counsel to help them with their reporting obligations under the law.

Refer to the calendar below for specific dates:

October 2014

  • Blue Cross begins collecting tax ID numbers along with other required reporting fields of information from subscribers and members.

December 2014

  • Blue Cross sends out first letter to members who enrolled from January 1 through November 30, 2014, with coverage that extends into or begins in 2015, who have yet to report their tax ID numbers to us.

January 2015

  • Blue Cross sends out first letter to members who enrolled December 1 through December 31, 2014, with coverage beginning in 2015, who have yet to report their tax ID numbers to us.

October 2015

  • Our collection of tax ID numbers is part of the enrollment process.

Q4 2015

  • For members enrolling from January 1 through November 30, 2015, Blue Cross sends a first letter requesting member tax ID numbers.
  • Blue Cross sends a second letter to all members who enrolled in a 2015 plan January through December 2014 who have not provided a member tax ID.

January 2016

  • Blue Cross sends our first letter to members who enrolled December 1 through December 31, 2015, with coverage beginning in 2016, who have yet report their tax ID numbers to us.
  • Blue Cross mails a 1095 form to subscribers (including member dependents) confirming proof of minimum essential coverage—including the tax IDs they provided for each member for the year 2015.

March 2016

  • Blue Cross electronically files reports to the IRS confirming members' 2015 minimum essential coverage.

April 2016 onward

  • The solicitation, collection of tax ID numbers, and reporting to the IRS for minimum essential coverage continues annually.

Blue Cross Blue Shield of Massachusetts

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