Do you have employees working in the following states: California, the District of Columbia, New Jersey, Rhode Island or Vermont? - Bim Group

Do you have employees working in the following states: California, the District of Columbia, New Jersey, Rhode Island or Vermont?

( 2 MINUTE READ )

If so, please continue reading.

Employers with operations in states who are Applicable Large Employers (ALE) (companies with 50 or more employees) have an  additional state level ACA reporting requirement as part of the state’s Individual Mandate.

The Individual Mandate requires individuals to purchase qualifying health coverage or pay a tax penalty unless they qualify for an exemption. The Mandate encourages residents who might otherwise not buy health insurance to do so in order for health insurance to be more evenly spread amongst the pool of covered individuals, and not just the sick. Employers too have a part to play under the statewide Individual Mandate. Currently California, Massachusetts, New Jersey, Rhode Island, Vermont, and the District of Columbia have Individual Mandates in place and require employers to report their ACA information on a state level.

If you have employees working in these states, please contact your ACA reporting provider to see if they can assist with state level reporting.

New Jersey

ALE will use IRS forms 1094-C and 1095-C, (1095-B, and 1094-B if self-insured) to communicate health insurance information to the state, in addition to their federal responsibilities for annually furnishing these forms to full-time employees and to the IRS. The deadline is March 31 of the following reporting year.

California

For the 2020 tax year, self-funded employers in California will need to report on the employees that had health coverage throughout the year. The information must be furnished to employees by January 31, 2021 and filed with California’s Franchise Tax Board by March 31, 2021.

Washington DC

In DC, every “applicable entity that provides Minimum Essential Coverage to an individual during a calendar year” is required to submit an information return regarding such coverage to the Office of Tax and Revenue (OTR).

It also requires the applicable entity to submit a statement about the individual’s type of coverage.

These filing requirements, while similar to Federal filing requirements under the ACA, are not the same. All information returns are required by OTR to be filed electronically through MyTaxDC, as paper filings will not be accepted. The new tax guidance requirements for annual reports are due beginning June 30, 2020. For future reporting years, the deadline for employers to file is 30 days after the federal IRS filing deadline.

Massachusetts

Massachusetts’s mandate has been in place since 2006. Employers do not have to report employee-level details to the state. The reporting is generally done by insurance carriers on behalf of individual employers. Employers must file by December 15th of the reporting year, much earlier than the federal filing deadline.

Vermont

Currently, there are no additional ACA reporting requirements for employers. Employers will have new coverage reporting obligations to the state only if the federal ACA reporting requirements are eliminated.

Rhode Island

Rhode Island’s individual penalty went into effect in January 2020. At this time, the only additional reporting requirements employers will need to comply with are the furnishing of healthcare receipts to employees beginning January 2021. The state has not disclosed whether the furnishing of health statements will be on the standard 1095-C or through a similar document. Employers with operations in Rhode Island should watch closely for updates.

 

Adapted from https://acatimes.com/aca-reporting-to-grow-in-complexity-due-to-state-individual-mandates/

Recent Insights

February 26, 2024
Compliance Alert, HHS

HHS Releases Updated Drug Data Collection Reporting Instructions in Advance of June 1, 2024, Deadline

Under Section 204 of the Consolidated Appropriations Act, 2021 (CAA), referred to as “The No Surprises Act” (NSA), all employer-sponsored health plans must satisfy certain transparency requirements by reporting annual prescription drug and health care spending data (often referred to as the Prescription Drug Data Collection (RxDC) report). The RxDC report is not only about […]
Read more
February 26, 2024
Compliance Alert

January 2024 Compliance Recap

READ TIME: 7 MINUTES January was a relatively quiet month on the employee benefits compliance front. The Wage and Hour Division of the Department of Labor (DOL) introduced a new rule laying out the guidelines employers can follow to determine how to classify workers. The DOL also released Part 64 of its FAQs about Affordable […]
Read more
January 31, 2024
News

2024 Employer-Sponsored Group Health Plans Compliance Calendar

Employers and HR departments are faced with many reporting and notification requirements for their employer-sponsored group health plans. Information must be provided to plan participants and applicable government agencies on time to ensure compliance with various federal laws. This compliance calendar outlines the requirements and due dates for: Form W-2 Form 5500 Forms 1094-B and […]
Read more
January 11, 2024
News

The Play-or-Pay Penalty and Counting Employees under the ACA

Since 2015, the Affordable Care Act (ACA) has required applicable large employers (ALEs) to offer their full-time employees health coverage or pay one of two shared responsibility penalties (ESRP or “play-or-pay”). An employer is an ALE if it employs 50 or more full-time or full-time equivalent employees. Final IRS regulations provide guidance to help employers […]
Read more