1. When determining if a subscriber has minimal creditable coverage (MCC) for a particular month, how should a month with coverage for less then the full month be handled?
  2. What if an individual is enrolled in MCC-compliant coverage for only part of the year?
  3. Do I need to submit my 1099HC form with my income tax returns?
  4. Is there a standard format for the Form MA 1099-HC?
  5. If an individual calls a carrier to request a copy of his or her form MA 1099-HC for a prior tax year, does a report also need to be sent to DOR electronically?
  6. If a subscriber has more than one mailing address, which address should be used on the Form MA 1099-HC? Which address should be sent to DOR electronically?
  7. Are carriers required to send Form MA 1099-HC letters to subscribers who reside in Massachusetts for only a portion of the year?
  8. What if a dependent has a different mailing address? Should the dependent receive a separate Form MA 1099-HC?
  9. If a parent company will be sending out Forms MA 1099-HC for its operating companies, what should appear in Line 1, the parent company name or the individual business entity's name?
  10. How many attempts do carriers have to make to deliver letters that are sent back as "undeliverable" via U.S. mail?
  11. Are carriers required to mail Forms MA 1099-HC to Medicare subscribers?
  12. What is the penalty for a health insurance carrier or employer that is obligated to issue Form MA 1099-HC but does not to comply?
  13. Is the FID number used for the Form MA 1099-HC the same as the FID number used for the IRS or other DOR filings?
  14. Do out-of-state welfare funds (union-sponsored multi-employer providers of health coverage) have to issue Form MA 1099-HC to Massachusetts residents?
  15. How can carriers or third party administrators issue 1099-HC documentation on behalf of plan sponsors when, due to the structure of benefits, how the benefits are arranged, or because multiple vendors are involved in the delivery of the plan, the carriers or third party administrators need the plan sponsors to certify that the total benefits package is MCC compliant?
  16. Are carriers or third party administrators required to submit the Attestation letter to DOR?
  17. Can the Attestation Letter be amended?
  18. Should 1099-HC's be sent to members with non-MCC compliant coverage?
  19. What if an individual had non-MCC compliant coverage for the entire year?

1. When determining if a subscriber has minimal creditable coverage (MCC) for a particular month, how should a month with coverage for less then the full month be handled.

A month is considered to be a month with coverage if the subscriber was covered for 15 days or more in the month and should be indicated as such on the 1099hc. If the subscriber had coverage for 14 days of less in a month, it is considered a month with out coverage.

Return to questions


2. What if an individual is enrolled in MCC-compliant coverage for only part of the year?

The months where the member was enrolled in non-MCC compliant coverage should be left blank. The only time a month on the 1099-HC should be filled in is when an individual was enrolled in MCC-compliant coverage for 15 days or more in the month.

Return to questions


3. Do I need to submit my 1099HC form with my income tax returns?

If you are filing a paper return, please attach a copy of your 1099 HC form to your tax return. If you have not received a copy of your 1099HC form, please attempt to obtain one from your insurance carrier. If you are unable to obtain a copy of your 1099HC form, you may submit your return without the form attached. Please be advised that this could delay the processing of your tax return. As always, electronic filing is the quickest and most efficient way to file your tax return with DOR.
 

Return to questions 


4. Is there a standard format for the Form MA 1099-HC?

No. There is no standardized format. The Form MA 1099-HC may vary depending upon each carrier; however the information fields must be consistent and must convey the information to the taxpayer that they need to transcribe over to the Schedule HC. A sample form pdf format of    1099_hc.pdf  is available on the DOR website.

Return to questions


5 . If an individual calls a carrier to request a copy of his or her Form MA 1099-HC for a prior tax year, does a report also need to be sent to DOR electronically?

Carriers need to send data for prior tax years, if the information wasn't sent in the original tax year. However, if the 1099-HC is a reprint, then it does not need to be sent to DOR electronically again unless the data changed.

Return to questions


6 . If a subscriber has more than one mailing address, which address should be used on the Form MA 1099-HC? Which address should be sent to DOR electronically?

The decision is up to the carrier. Just make sure what is sent to DOR and what is sent to the taxpayer is consistent.

Return to questions


7 . Are carriers required to send Form MA 1099-HC letters to subscribers who reside in Massachusetts for only a portion of the year?

Carriers will decide for themselves who to send Form MA 1099-HCs to in cases where residency is not clear. However, a person's address for insurance purposes and for tax purposes may be different. The carriers should be prepared to generate Form MA 1099-HCs as needed for these individuals on request.

Return to questions


8 . What if a dependent has a different mailing address? Should the dependent receive a separate Form MA 1099-HC?

The only formal requirement is that the Form MA 1099-HC be sent to the primary subscriber. Dependents are not required to receive Form MA 1099-HC. However, carriers may send separate Forms MA 1099-HC to dependents if they so choose. It is left up to the carrier how they handle these requests.

Return to questions


9 . If a parent company will be sending out Forms MA 1099-HC for its operating companies, what should appear in Line 1, the parent company name or the individual business entity's name?

The DOR will not distinguish between the parent company's name, and the individual business entity's name. However, it is critical that what is reported to DOR electronically and what is sent to the taxpayer on the Form MA 1099-HC matches exactly for both the name and FID number. Carriers are encouraged to use the name that would be least confusing for the taxpayer, taking what is listed on their enrollment card into consideration.

Return to questions


10 . How many attempts do carriers have to make to deliver letters that are sent back as "undeliverable" via U.S. mail?

This is an internal decision of the carrier. There is no tax information on the Form MA 1099-HC and therefore DOR has no position on mail returned from the post office.

Return to questions


11 . Are carriers required to mail Forms MA 1099-HC to Medicare subscribers?

No. DOR will not require carriers to send Form MA 1099-HC to their Medicare members. This applies to both Supplemental or Replacement plans.

Return to questions


12. What is the penalty for a health insurance carrier or employer that is obligated to issue Form MA 1099-HC but does not to comply?

The 1099 HC is a tax document like any other tax document required to be submitted to the Massachusetts Department of Revenue by law or regulation. Failure to do so could subject the employer or carrier to a host of penalties, as provided under M.G.L. Ch. 62C § 8B. Below is the language contained in DOR's regulation.

(9) Penalty for Failure to Provide Documentation of Health Insurance

(a) Pursuant to M.G.L. c. 62C, § 8B, carriers, employers or other sponsors of employment-sponsored health plans that fail to provide written statements to covered individuals or to report to the Commissioner in violation of this section shall be punishable by a penalty of $50 per individual to which the failure relates, not to exceed $50,000 per year per violator.

(b) The Commissioner shall assess the penalties under M.G.L. c. 62C, § 8B as a tax subject to chapter 62C. 

Return to questions 


13. Is the FID number used for the Form MA 1099-HC the same as the FID number used for the IRS or other DOR filings?

Not necessarily. It is important that taxpayers report the FID number as shown in Box 2 of the Form MA 1099-HC on their tax return. The number that is reported on the Form MA 1099-HC, which is sent to the subscriber is not necessarily the same number that a carrier may use for other tax reporting requirements.

Return to questions


14. Do out-of-state welfare funds (union-sponsored multi-employer providers of health coverage) have to issue Form MA 1099-HC to Massachusetts residents?

The Department's regulation requires 1099-HC reporting in the case of employment-sponsored health plans if an employer is doing business in the state (i.e. has employees working in the Commonwealth). The pertinent part of the regulation is set out below. Assuming that an employer is doing business in Massachusetts, the reporting is required with respect to its Massachusetts resident employees, regardless of their work location.

The Department's primary goal is to implement the statutory health insurance requirements, as they affect either employers or resident individuals, with as little burden as possible. A number of non-Massachusetts employer plans are voluntarily reporting on behalf of Massachusetts resident employees even though, as a jurisdictional matter, the statutory reporting requirements may not extend to them. The reporting is a convenience to the employees, as it provides them with information requested on the Massachusetts income tax return. And while a resident who does not receive a 1099-HC is nevertheless able to complete and file a Massachusetts resident return indicating compliance with the state health care mandate, the Department will be conducting automated matches to confirm compliance. If an employer has provided 1099-HCs and verifying reports of coverage to the Department, unnecessary follow-up with employees may be avoided.

Return to questions


15. How can carriers or third party administrators issue 1099-HC documentation on behalf of plan sponsors when, due to the structure of benefits, how the benefits are arranged, or because multiple vendors are involved in the delivery of the plan, the carriers or third party administrators need the plan sponsors to certify that the total benefits package is MCC compliant?

The Attestation Letter pdf format of    Attestation Letter  may be used by a plan sponsor to certify to a medical carrier or third party administrator that the package of benefits provided to covered employees is indeed MCC compliant, even if the portion provided by the medical carrier on its own, would not meet these standards. The medical carrier or third party administrator may use this certification for the purpose of providing 1099-HC's directly to individuals covered and providing DOR with a list of MA residents covered by the MCC-compliant health benefits plan.

Return to questions


16. Are carriers or third party administrators required to submit the Attestation letter to DOR?

No. Carriers and third party administrators should keep the attestation letters on file and make them available to DOR upon request.

Return to questions


17. Can the Attestation Letter be amended?

Yes. Carriers may add but not subtract from the Attestation letter, as needed, to facilitate the issuance of the 1099-HC's.

Return to questions


18.Should 1099-HC's be sent to members with non-MCC compliant coverage? 

Yes. Members with non-MCC compliant coverage should receive a 1099-HC indicating that their coverage was not in compliance with the MCC standards. Issuing the 1099-HC to the taxpayer will reduce taxpayer confusion regarding their health care status as well as calls to carriers seeking a 1099-HC.

Return to questions


19. What if an individual had non-MCC compliant coverage for the entire year?

The No field in the full-year minimum creditable coverage section of the 1099-HC should be filled in.

Return to questions