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Employers ASO group compliance calendar

To ensure ASO group remains in compliance and your employees stay covered, review our key compliance resources and due dates.

January

Due: January 31

Form 1095-B

Form 1095-B will be available online via the Blue Connect member portal. Form 1095-B is used to report certain information to the IRS and to taxpayers about individuals who are covered by minimum essential coverage and therefore are not liable for the individual shared responsibility payment.

Due: January 31

Form 1095-C

ASO groups are responsible for preparing the Form 1095-C member-level forms. Blue Cross NC creates the Internal Revenue Code (IRC) 6055 report to assist groups with this process. ASO Group members will receive a 1095-C form from their Group Administrator. Blue Cross NC sends the IRC 6055 Reporting, on request, to provide groups with the information they need to complete and file the forms.

Due: January 31

IRC 6055 Report

This report is provided to all ASO groups upon request. The Affordable Care Act added section 6055 to the Internal Revenue Code (IRC) requiring every provider of minimum essential coverage to report coverage information by filing a return with the IRS and furnishing a statement to individuals by January 31 each year. This information is submitted using the 1095-B or 1095-C form (depending on the type of coverage offered by a given group).

  • For ASO groups, the group is the insurance provider and must submit coverage information to the IRS and provide statements to all their covered members.
  • To assist with this process, Blue Cross NC produces the IRC 6055 Report for all ASO groups (including Balanced Funding groups) on an annual basis, which can be sent if requested by the group

Due: January 31

Form MA1099HC

Massachusetts’ health care law requires most residents ages 18 and older to have health insurance. Blue Cross and Blue Shield of North Carolina (Blue Cross NC) provides an MA1099HC form to help our self-funded group members who live in Massachusetts prove their state’s minimum creditable coverage (MCC).

March

DUE: March 31

MA1099-HC Electronic Bulk filing

This user guide⁠ shares the requirements for electronically filing multiple Massachusetts Healthcare Coverage (1099-HC) documents. 

June

DUE: June 1

Prescription Drug Data Collection (RxDC) reporting

Review the requirements for the Consolidated Appropriations Act (CAA) RxDC Reporting.

July

DUE: July 31

Patient-Centered Outcomes Research Institute (PCORI)

The PCORI fee⁠ is imposed on an issuer of a specified health insurance policy and a plan sponsor of an applicable self-insured health plan based on the average number of lives covered under the policy for the policy year or the plan for the plan year. For ASO groups, the group is the insurance provider and must submit coverage information and payment to the IRS.

October

DUE: October 15

Annual Medicare Part D notices to participants are due

Medicare-eligible policyholders must be notified whether their prescription drug coverage is creditable coverage⁠, which means that the coverage is expected to pay on average as much as the standard Medicare prescription drug coverage. Blue Cross NC mails group analysis notices around October 1, 2024, to all groups in the small group (1-50) market. Blue Cross NC shares group analysis notices annually, around October 1, for all groups with employers (via the Employer News channel on our Employer Services portal), and agents (via Agent News on our Agent Services portal). Employer groups must communicate their creditable or non-creditable status to their members.

December

DUE: December 31

Gag Clause Attestation due

All employers offering group health insurance and group health plan sponsors offering balance funded or self-funded coverage must submit an annual Gag Clause Prohibition Compliance Attestation (GCPCA) to the Centers for Medicare & Medicaid Services (CMS).

Enrollment resources

Compliance guidelines require you to provide this information to employees at open enrollment and upon new plan enrollment.

HIPAA Notice of Special Enrollment Rights

Notice to participants on how the group health plan intends to handle the participant’s personal health information, as well as the privacy practices of the plan.

Summary of Plan Description (SPD)

Distribution of the SPD informs participants and beneficiaries about their plan and how it operates. The plan must be written for an average participant and be sufficiently comprehensive to apprise covered persons of their benefits, rights, and obligations under the plan.

Women’s Health and Cancer Rights Act Notice (WHCRA)

Notice to participants and beneficiaries describing the plan's coverage of mastectomy-related services, including reconstructive surgery, prosthesis and lymphedema.

Surprise billing rights and protections

Learn about member rights and protections against surprise medical bills that can cost thousands of dollars, depending on the procedure or service.

Summary of Benefits and Coverage (SBC) Glossary

Notice to plan participants to provide standard information to compare plans and to make informed decisions regarding plan offerings.