The Rise of the State Individual Health Coverage Mandates
ACA Reporting Software and Outsourcing Solutions
Several states have enacted individual health coverage mandates requiring taxpayers to provide proof of coverage to avoid penalties. These mandates require electronic filing—no state currently accepts paper forms. Our software and outsourcing solutions help employers prepare and file Forms 1095-B and 1095-C to remain compliant.
Outsourcing Solutions...
Our trained staff can import, print, mail, and electronically file Forms 1094/1095 with the IRS and individual states. Once filed, we forward you the file status, typically within 1–3 days.
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Residents are subject to these state mandates if they lived in the District of Columbia, New Jersey, California, Rhode Island, or Vermont for any part of the tax year. Employers and providers of minimum essential coverage with employees in these states must file Forms 1095-B or 1095-C.
New Jersey
The New Jersey Health Insurance Market Preservation Act (HIMPA) requires employers and other providers of minimum essential coverage to file Forms 1095-B and/or 1095-C with the Division of Taxation by March 31 each year.
Employers with New Jersey residents must:
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Send a health coverage verification form to each New Jersey enrollee by March 2.
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Electronically file Form 1095-B or 1095-C through the Division of Revenue and Enterprise Services’ MFT SecureTransport system by March 31.
Paper filing is not accepted—forms must be submitted electronically.
The District of Columbia individual mandate requires all DC residents to have minimum essential health insurance, claim an exemption, or pay a penalty on their tax return.
Who Must File
Insurance companies, employers, and other entities that provide minimum essential coverage to DC residents must electronically file Forms 1095-B or 1095-C through the DC Office of Tax and Revenue (OTR) portal.
Filing Notes
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DC requires a special pipe-delimited text file (XML is not accepted).
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No paper filing options are available.
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The deadline is April 30, 30 days after the federal deadline for IRS filing.
California requires residents to maintain health coverage year-round, obtain an exemption, or pay a penalty when filing state taxes. This applies to each resident, spouse, or domestic partner.
Employer Filing Requirements
Employers must:
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Provide employees with Form 1095-B or 1095-C by January 31.
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Submit ACA returns to the California Franchise Tax Board (FTB) by March 31.
Rhode Island mandates qualifying health coverage throughout the year, an exemption, or a penalty when residents file their state tax returns. This applies to each resident, spouse or domestic partner, and dependents.
The mandate helps maintain a stable health insurance exchange by keeping more individuals insured. Employers must electronically submit 1095 forms on behalf of covered residents.
Vermont requires most residents over age 18 to maintain health insurance and report coverage on their tax returns.
Employer Filing Notes
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Vermont does not require electronic submission of 1095 forms to the state.
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Employers only need to follow the federal ACA requirement to distribute Form 1095-C to employees.