ICHRA Reporting Requirements

An ICHRA is a group health plan and will be subject to ERISA. All the rules generally applicable to ERISA plans will apply to an ICHRA. It's important for brokers to stay informed about the reporting requirements associated with ICHRA. Groups will also need to adhere to state requirements for Massachusetts.

W-2 Reporting Requirements: Under the ACA, employers are mandated to report the cost of employer-sponsored group health plans. However, the IRS does not require reporting of ICHRA benefits on Form W-2. This alleviates the burden of W-2 reporting for employers who offer ICHRA.

Small Group Reporting Requirements: For employers offering ICHRA, compliance entails submitting Form 1094-B and Form 1095-B to the IRS. Form 1095-B provides crucial information about the coverage offered to employees, requiring a submission for every employee enrolled in ICHRA during the plan year. Form 1094-B serves as a summary sheet, consolidating the total number of 1095-B forms that were submitted.

Reporting for Applicable Large Employers (ALEs): ALEs, defined as employers with 50 or more Full-Time Equivalent employees (FTEs), must adhere to the ACA's employer mandate. This includes submitting Form 1094-C to the IRS, detailing the coverage offered to employees during the tax year. Additionally, Form 1095-C must be provided to full-time employees, explaining how affordability is calculated.

HRA administrators often support the employer with 1095 reporting, but do not manage the fillings.

Form 5500: Employers offering an ICHRA must file Form 5500. This document outlines the financial condition and operations of the employer's benefit plans for the year. Brokers play a pivotal role in facilitating the completion and submission of Form 5500.

HIRD Form and EMAC Reporting: In Massachusetts, employers must navigate additional reporting obligations, such as the Health Insurance Responsibility Disclosure (HIRD) form and Employer Medical Assistance Contribution (EMAC) reporting.

The HIRD form collects employer-sponsored health plan information to identify members who may be eligible for premium assistance. Employers with 6 or more MA employees, regardless of whether they offer health insurance, must disclose whether they offered to pay for their MA employees’ healthcare insurance. HIRD states that employers do not need to report on HRAs, FSAs and HSAs, but employers offering ICHRA should still submit HIRD forms to report on offered contribution amounts.

EMAC: Each employer subject to unemployment insurance is also subject to Employer Medical Assistance Contribution (EMAC) reporting requirements. EMAC is used to help fund health insurance programs in the Commonwealth.

Employers should work with their accountant for more detailed tax information if they have more specific questions about tax reporting.

Reach out to our HSA ICHRA Support Team with questions. You can reach the team at ichra@hsainsurance.com or call 781-228-2222, option 4.