The Rise of the State Individual Health Coverage Mandates
ACA Reporting Software and Outsourcing Solutions
Several states have enacted their own individual mandates requiring taxpayers to provide proof of health coverage
to avoid financial penalties. All states that have enacted mandates require an electronic file to be remitted to them by a certain due
date. No state thus far accepts paper filed forms.
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Residents are subject to these state mandates irrespective of the stay of duration. Anyone who had a home or mailing
address in the District of Columbia or state of New Jersey, California, Rhode Island or Vermont for any period
of time during that calendar year should be included in your reporting.
New Jersey
The New Jersey Health Insurance Market Preservation Act (HIMPA) requires employers
and all other providers of minimum essential coverage to file 1095-B and/or 1095-C information returns with the
Division of Taxation on or before March 31, 2020. This applies to both part-year and full-year New Jersey residents.
New Jersey requires its residents to have minimum essential health coverage and failure to have health coverage will
result in a shared responsibility payment.
The state expects New Jersey employers and out-of-state employers with NJ residents to:
- Send the appropriate 1095 health coverage verification form to each New Jersey enrollee (usually the employee or purchaser of the policy) by March 2. This applies to both part-year and full-year New Jersey residents.
- Electronically remit Form 1095-C or 1095-B through the Division of Revenue and Enterprise Services’ MFT SecureTransport service. The due date is March 31. An employer can not paper file these forms; the data must be sent electronically.
District of Columbia
The District of Columbia individual mandate requires all DC residents to have minimum essential health insurance
coverage, to get an exemption, or pay a tax penalty on their tax returns. The mandate applies to DC residents
only.
Insurance companies, businesses providing insurance to their employees, and other
applicable entities that provide minimum essential coverage to someone who lives in the District of Columbia are
required to electronically file 1095-B or 1095-C forms via the DC Office of Tax and Revenue (OTR) web portal.
The District of Columbia requires a very unique pipe delimited notepad file. The XML that you would transmit to the
IRS is not accepted.
The due date is April 30 which is 30 days after the IRS deadline for submitting 1095-B or 1095-C forms. There are no paper filing options.
California
California was among the states that passed an individual mandate that required residents to
maintain minimum essential coverage (MEC). The state of California requires residents to
maintain qualifying health insurance throughout the year, obtain an exemption, or pay a penalty when they file
their state tax return. This requirement applies to each resident, their spouse or domestic partner.
Employers must provide 1095 forms (1095-B or 1095-C) to employees by January 31st following the end of the plan year.
Employers must submit returns to the FTB by March 31st following the end of the plan year.
Rhode Island
Rhode Island requires residents to maintain qualifying health
insurance throughout the year, obtain an exemption, or pay a penalty when they file their state tax
return. This requirement applies to each resident, their spouse or domestic partner,
and their dependents. These states joined a growing list of states that impose an individual
mandate on their residents to keep younger and healthier individuals in the exchange market pool.
Vermont
Vermont's mandate requires most Vermont residents over the age of 18 to acquire health
insurance coverage and submit their tax forms. However, Vermont only requires employers to follow the
federal requirement to distribute 1095-C forms and do not require electronic filing to Vermont itself.
Future State Mandates...
Hawaii, Washington, Connecticut, Minnesota and Maryland are considering their own state healthcare mandates.
Related...
ACA state mandates, ACA individual state mandates, Minimum Essential Coverage (MEC), ACA Employer Mandate, ACA Reporting
