2015 1095-A Corrections
For 1095-As that report incorrect information Covered California has switched from a paper form to an online submission form or call the service center at 1-800-300-1506.
The online 1095-A correction request form is great if it sends a copy of the submission to the consumer via email once it is submitted. (At the time of this update I don’t have confirmation that online submission form is being carbon copied to the consumer.) The form will only allow the consumer to dispute or ask for a correction for certain elements of the 1095-A.
- I never got a Form 1095-A from Covered California
- The wrong amount of premium assistance (tax credits or APTC) is listed on Form 1095-A
- The wrong months of coverage are listed
- Some months you had health insurance are not shown
- The wrong start date or end date is shown for covered individuals
- The wrong policy start date or end date is shown
- There are missing household members or wrong names
- My health coverage was terminated
Demographic information such as the wrong address isn’t available to be changed with the form. But according a Center for Medicare and Medicaid Services webinar on the 1095-As, “Incorrect demographic information (for example, name, date of birth, or Social Security Number), can be updated directly by the consumer when they file their federal income tax return without the need to generate a corrected Form 1095‐A” – slide 14.
- [wpfilebase tag=fileurl id=1331 linktext=’ CMS Getting Ready for Tax Season’ /]
Consumer’s will only receive a 1095-A from Covered California for their enrollment in a health plan through the exchange. A 1095-B for health insurance provided by Medi-Cal will come from the Department of Health Care Services. A 1095-B will be supply for small employer group health plans with 50 and fewer employees. A 1095-C for health insurance provided by an Applicable Large Employer group plan will come from the company. But the companies don’t have to send the 1095-B and Cs until March.
Other documents that will provide additional information:
- [wpfilebase tag=file id=1327 /]
- [wpfilebase tag=file id=1328 /]
- [wpfilebase tag=file id=1329 /]
- [wpfilebase tag=file id=1330 /]
For taxpayers who received Advance Premium Tax Credits through Covered California or another Marketplace exchange, completing their 2014 taxes may be as simple as handing over their Form 1095-A Health Insurance Marketplace Statement to their tax preparer. However, if that 1095-A is incorrect for any reason, the tax payer may have to invest significant time to get a corrected copy. A January presentation on Form 1095-A from Covered California went over getting a corrected 1095-A, making changes to the 2014 account, and how not to expect much help from exchange itself.
- See also: 1095-A reveals excess tax credits paid to Anthem Blue Cross from Covered California – Covered California reported tax credits, paid to Anthem Blue Cross, on consumer’s 1095-A after the consumer had already left the Blue Cross Enhanced Silver Plan.
March 20, 2015 Update: IRS waives ACA premium taxes
The Treasury Department has decided to expand their February 24 announcement waiving collection of under reported health insurance tax credits to states that are running their own Marketplace exchanges. Tax payers who already filed their tax returns using incorrect 1095-As issued by Covered California will not be subject to the collection of excess Advance Premium Tax Credits (APTC) not reported on the 1095-As. This is a very limited decision by the Treasury Department and does not vacate the responsibility of tax payers waiting for a corrected 1095-A to from repaying any APTC they may owe. Read more with down loads -> IRS waives tax collection from incorrect Covered California 1095-As
March 16, 2015 Covered California Update
Covered California issued a news brief related to their progress to issue correct 1095-As and send out the important IRS form for people who have not received them. In short-
- Starting March 16th, 2015, Covered California will begin calling people who have filed the 1095-A dispute form and notifying them of the status. (I assume if you get a phone call instead of a correct 1095-A that means they have either denied the dispute or they need more information.)
- Consumers should check their secure Covered California inbox to see if a corrected 1095-A has been sent. The letter will indicate it is a NOD-62B for corrected 1095-A.
- If a consumer hasn’t heard from Covered California after 60 days, they should call and find out what the heck is taking so long.
- Consumers who NEVER received a 1095-A should check to make sure they Covered California has their current and correct address. They should also immediately file the 1095-A Dispute Form. ([wpfilebase tag=fileurl id=433 linktext=’1095-A Dispute Form Covered California’ /])
For a copy of the full news brief download –
- [wpfilebase tag=fileurl id=621 linktext=’March 16th Important Update on 1095-A Corrections’ /]
10,000 Californians without 1095-As
California Healthcare Foundation Center for Health Reporting quoted Covered California’s Dana Howard as stating that there are an estimated 10,000 tax filers who have not received a 1095-A at all. Covered California is blaming the lack of the crucial tax document on conflicting account information. See the full story at Obamacare’s tax-time lessons by Emily Bazar
Healthcare.gov corrected 1095-A
About 20 percent of the tax filers who had Federally-facilitated Marketplace coverage in 2014 and used tax credits to lower their premium costs – about 800,000 (< 1% of total tax filers) – will soon receive an updated Form 1095-A because the original version they were issued listed an incorrect benchmark plan premium amount. Based upon preliminary estimates, we understand that approximately 90-95% of these tax filers haven’t filed their tax return yet. We are advising them to wait until the first week of March when they receive their new form or go online for correct information before filing. For those who have filed their taxes — approximately 50,000 (< 0.05% of total tax filers) – the Treasury Department will provide additional information soon. – Read the full CMS blog release at What Consumers Need to Know about Corrected Form 1095-As
Treasury Department incorrect 1095-A
CMS released detailed information about the error, which is available here. Treasury estimates that approximately 50,000 tax filers (or less than 0.05% of total tax filers) already have filed their taxes using these incorrect form 1095As. We have concluded that these individuals do not need to file amended returns. The IRS will not pursue the collection of any additional taxes from these individuals based on updated information in the corrected forms. For more information see – Statement from a Treasury Spokesperson on CMS Announcement Last Week about 1095-A Forms:
There is no indication that the relief from filing an amended return applies to incorrect 1095-As issued by Covered California.
Covered California February Postcards
Some Covered California members received a version of IRS Form 1095-A that contained inaccuracies. In order to communicate this, Covered California will be mailing out a postcard to those consumers informing them of the inconsistencies and making them aware that a corrected version of IRS Form 1095-A will be issued to them for tax filing purposes.
The postcard states,
You recently received an IRS Form 1095-A from Covered California. We are writing to tell you that we discovered a problem with the information on your original from. Covered California is in the process of updating the information and will send you a corrected 1095-A with the next couple of weeks. Please use the corrected IRS Form 1095-A information when filing your federal income tax or amending your federal income tax if you have already filed your tax return. The corrected IRS Form 1095-A will have a checkbox marked as corrected at the top of the form.
You can also log into your CoveredCa.com account and go to your secure mailbox to download a copy of your corrected Form 1095-A once it becomes available.
If you have questions or have not received your corrected IRS Form 1095-A by mid-February, please call the Covered California Consumer Service Center at 1-800-300-1506 Monday through Friday, 8:00 AM – 8:00 PM; Saturday and Sunday, 8:00 AM – 6:00 PM.
Covered California 1095-A Training Video
Covered California put together a 38 minute video presentation on Form 1095-A and the role of the different service channels (aka: agent, enrollers, staff) play in assisting consumers with understanding the Health Insurance Marketplace Statement. The statement or Form 1095-A will be a receipt of the tax credits forwarded to the health insurance company on the consumer’s behalf by either Covered California or another Marketplace exchange such as Healthcare.gov or other state exchange. Download the slide deck of the training presentation at the end of the post.
Few real life scenarios discussed
A consistent theme with both IRS and Covered California guidance is the lack of recognition about the variety of different household situations that used the Marketplace for ACA tax credits to lower their health insurance premium. For example, neither has discussed how a tax payer may receive multiple statements because they possibly enrolled through both state and federal exchanges for health insurance in 2014. Many households will experience life events such as marriage, divorce, births, deaths and moving to another residence during the year. Every one of these events, if not properly reported at the time of the event, can lead to incorrect Form 1095-A.
ACA enrollment may generate 1095-A errors
Then there are simple errors that develop from not understanding the online enrollment and ACA requirements in the first place. Some tax payers included adult children as dependents before they knew they wouldn’t be able to claim them as a dependent in 2014. Then there are system errors that enrolled individuals and families in both a private plan AND Medi-Cal at the same time. These individuals, who made there premium payments without knowing they also had Medi-Cal, will receive a 1095-A for tax credits they weren’t due and shouldn’t have to report on their taxes.
Who won’t get a 1095-A?
The Covered California training 1095-A training starts off with defining who will receive a 1095-A in the first place. (The first nine minutes of the video is happy talk and of no real substance). For individuals who enrolled for health insurance through Covered California, the following tax payers will NOT receive a Form 1095-A Health Insurance Marketplace Statement
- Employees enrolled in a SHOP small group plan
- Households members who qualified for Medi-Cal
Also be aware of a couple different situations –
- If you were eligible for tax credits, then your income dropped placing the household in Medi-Cal/Medicaid, you’ll get a 1095-A for the months you received tax credits.
- If your household income made your children eligible for Children’s Medi-Cal, the 1095-A will only reflect the tax credits paid on behalf of any adults on the plan.
Who will get multiple 1095-A’s?
While some folks will receive no 1095-A from Covered California, some individuals and families will received two or more statements.
- If members of the tax household changed policies during the year
- The family changed metal tier levels with the same carrier and plan
- The household enrolled in a different plan
- There are six or more members of the tax household
Essentially, if you are a normal household that had a qualifying event such as birth, marriage, divorce, death, or move that allowed you to modify your health insurance plan, you’ll get two 1095-A’s. These multiple 1095-A’s will need to be used to fill out Form 8962. Can you imagine if two different 1095-A’s show tax credits being paid for the same month to different plans? Aye curumba, what a nightmare. The taxpayer will most likely get stuck paying back the excess tax credits.
Getting a corrected 1095-A Marketplace statement
Now that the taxpayer has one or more 1095-A’s that are incorrect, how does one make a correction so the numbers can be properly reported on Form 8962 Premium Tax Credit. Some changes can actually be handled through the household’s Covered California account. The Continue or Report a Change 2014 link will allow the changes to just 2014 information. Changes made with this link between January 12th and March 1st will result in a corrected 1095-A being generated. This is where you would want to remove that adult child who you found out you can’t claim as a dependent after all.
The Report a Change 2014 link will work for changes to –
- Date of Birth
- Social Security Number
- Household Members
Changing 2014 income
A change to the income will have no effect. The Advance Premium Tax Credits have already been paid to the health insurance company. The increase or decrease of income won’t add or subtract amounts that have already been paid. Form 8962 Premium Tax Credit reconciles the final household income with the tax credits reported on 1095-A. The reconciliation will determine if the household owes the repayment of excess Advance Premium Tax Credits or will receive more tax credits from the IRS because of their final Modified Adjusted Gross Income.
California 1095-A Dispute Form
However, there may be situations where making a change to the account can’t correct the original 1095-A or there were errors in the amounts reported. Covered California has developed the 1095-A Dispute Form to report issues with a taxpayers original statement. Most forms can be found on my IRS-ACA page. Households can use the 1095-A Dispute Form to report a variety of issues such as
- Never receiving a 1095-A from Covered California
- Wrong amount of premium assistance is reported on 1095-A
- Wrong months of coverage are listed
- Some months of coverage are not included on the 1095-A
- Wrong start and end dates of health plans
- Missing household members or wrong names
- Health coverage was terminated in 2014
- Other problem…please explain
[wpfilebase tag=fileurl id=433 linktext=’1095-A Dispute Form Covered California’ /]
Headache inducing reconciliation
With respect to disputing the wrong amount of Advance Premium Tax Credit, this may necessitate a full accounting of health insurance premiums billed and paid. A taxpayer disputing the APTC may need to get information from not only Covered California but from the health plan as well. It’s likely that reconciling each months premiums with credits applied will take some time and don’t expect Covered California or your tax preparer to accomplish this for you. While the 1095-A Dispute Form lists an authorized represented that can file this form on behalf of the household, again, don’t expect too much help from any of these entities.
Don’t expect much guvment help
It would be wonderful to expect Covered California Certified Insurance Agents, Certified Enrollment Counselors, Certified Enrollment Entities, Navigators and Plan Based Enrollers to walk with ACA households the extra mile when it comes to changing 2014 information or disputing APTC reported on the 1095-A, but the compensation system is not in place to support these activities. (Most Certified Insurance Agents designated by the consumer should be happy to change 2014 data for their clients.) Consequently, when some households most in need of assistance for managing health insurance tax credits under the ACA, there will be few people around to help. Even the IRS has stated that they will not be able most of the calls for assistance.
IRS update February 9, 2015
Issue Number: IRS Tax Tip 2015-15
Note: Important New Health Insurance Form. If you bought health insurance through the Health Insurance Marketplace, you should have received a Form 1095-A, Health Insurance Marketplace Statement, by early February. You will need the new form to help you complete an accurate federal tax return. You will use the information from the Form 1095-A to calculate the amount of your premium tax credit. The form is also used to reconcile advance payments of the premium tax credit made on your behalf with the amount of premium tax credit that you are eligible to claim.
If you did not receive your Form 1095-A, you should contact the Marketplace from which you received coverage to get a copy. You are not required to send in proof of health care coverage, including Form 1095-A, to the IRS when filing your tax return. However, it’s a good idea to keep these records on hand to verify coverage.
New Covered California video on 1095-A
Covered California 1095-A Training Slides
- [wpfilebase tag=fileurl id=425 linktext=’1095-A Covered California Training Slides’ /]