IRS intends to propose reporting rules for certain types of health care coverage

The Treasury Department and the IRS intend to propose regulations under Code Sec. 6055: (1) providing that health insurance issuers must report coverage in catastrophic health insurance plans described in §1302(e) of the Patient Protection and Affordable Care Act enrolled in through a Health Insurance Exchange; (2) allowing electronic delivery of statements reporting coverage under expatriate health plans unless the recipient explicitly refuses consent or requests a paper statement; (3) allowing filers reporting on insured group health plans to use a truncated taxpayer identification number (TTIN) to identify the employer on the statement furnished to a taxpayer; and (4) specifying when a provider of minimum essential coverage is not required to report coverage of an individual who has other minimum essential coverage. The notice also advises that the governments of United States possessions or territories are not required to report coverage under Medicaid and the Children’s Health Insurance Program (CHIP) and provides that the state government agency sponsoring coverage under the Basic Health Program is required to report Basic Health Program coverage.

In addition, pending the issuance of additional guidance, reporting entities will not be subject to penalties for failure to report a taxpayer identification number (TIN) if they comply with the requirements of Reg. §301.6724-1(e) with the following modifications: (1) the initial solicitation is made at an individual’s first enrollment or, if already enrolled on September 17, 2015, the next open season; (2) the second solicitation is made at a reasonable time thereafter; and (3) the third solicitation is made by December 31 of the year following the initial solicitation. Additionally, a reporting entity is not required to solicit a TIN from an individual whose coverage is terminated.

Comments requested. The IRS and Treasury Department are requesting comments on issues relating to the solicitation of covered individuals’ TINs and on the application of the reasonable good cause rules under Code Sec. 6724 to Code Sec. 6055 reporting, and in particular the rules under Reg. §301.6724-1(e) relating to TIN solicitation and reporting.

Comments may be submitted in writing on or before November 16, 2015. Comments should be mailed to the Internal Revenue Service, CC:PA:LPD:PR (Notice 2015-68), Room 5203, P.O. Box 7604, Ben Franklin Station, Washington, D.C. 20044, or submitted electronically to Please include “Notice 2015-68″ in the subject line of any electronic communications. Alternatively, comments may be hand delivered between the hours of 8:00 a.m. and 4:00 p.m. Monday to Friday to CC:PA:LPD:PR (Notice 2015-68), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue NW., Washington, D.C.

SOURCE: IRS Notice 2015-68, I.R.B. 2015-41, October 13, 2015.

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