Massachusetts has issued the minimum creditable coverage (MCC) cost of living adjustments for the 2022 tax year. As a reminder, Massachusetts requires most state residents to maintain minimum creditable coverage or be subject to a state tax. The law does not impose an obligation on employers to offer minimum creditable coverage. It does require health plans to provide a 1099-HC reflecting whether the coverage offered meets minimum creditable coverage standards.

The 1099-HC must be provided no later than January 31 of the following year. The 1099-HC only needs to be provided to the primary subscriber. The 1099-HC can be sent by mail or if the subscriber consents, the 1099-HC can be sent electronically.

Cost of living adjustments

An MCC-compliant health plan may impose varied levels of co-payments, deductibles and coinsurance (see table below for limits), as long as the plan discloses, to the insured, the relevant deductible, co-pay and co-insurance amounts applicable to both in and out-of-network services.

*Note: The out-of-pocket limit is higher than the ACA’s 2022 limits which are $8,700/$17,400 as set by the Notice of Payment and Parameters for 2022.Whether Massachusetts will modify their standards remains to be seen. Be aware though to be ACA compliant, the ACA standards must be met.

An HSA-compatible high deductible health plan can qualify as minimum creditable coverage if the plan covers core services, a broad range of medical benefits, and facilitates access to a health savings account (HSA), i.e., the plan sponsor and/or insurer must provide information to individuals explaining how to establish and fund an HSA.

In addition and as a reminder, every employer in Massachusetts with six or more employees must annually submit a Health Insurance Responsibility Disclosure (HIRD) form. The HIRD form collects information about the health coverage offered by Massachusetts employers to their employees.

The HIRD form may be filed by either the employer or the employer’s payroll company; however, it is the employer’s responsibility to ensure that the HIRD form is timely filed. HIRD reporting is due by November 30 of each year with the current year’s information. Employers that do not offer any health coverage still must file a HIRD report.

The information contained in this Benefit Beat is not intended to be legal, accounting, or other professional advice, nor are these comments directed to specific situations. This information is provided as general guidance and may be affected by changes in law or regulation. This information is not intended to replace or substitute for accounting or other professional advice. You must consult your own attorney or tax advisor for assistance in specific situations. This information is provided as-is, with no warranties of any kind. CBIZ shall not be liable for any damages whatsoever in connection with its use and assumes no obligation to inform the reader of any changes in laws or other factors that could affect the information contained herein.