2022 ACA Reporting State Requirements

April 28, 2023

Summary

Once the ACA individual mandate was removed at the federal level on January 1, 2019, six states adopted individual mandates, often with added reporting requirements. Employers may want to verify states where employees reside and refresh their knowledge. Review the chart below for a summary by state and read details in this third-party article.

California (CA)

CA parallels federal ACA requirements: an employer must complete Part 1 of Form 1094-C and required Forms 1095-C. Regarding Form 1095-C, only self-insured plans should submit and only if the individual accepted coverage. Click here to learn more about the deadlines and penalties.

Learn More

Massachusetts (MA)

ACA required forms are not the same as the Form 1095-C. Be sure to review MA rules for form directions. The Form MA 1099-HC must be sent to applicable employees by January 31 and filed with the State by March 31. Penalties for failure to file are $50 per person up to a $50K max.

Learn More

New Jersey (NJ)

NJ only requires self-insured employers to submit a Form 1095-C to the State by March 31, and by March 2 to employees. Note that fully insured plans retain fiduciary responsibility if carriers do not submit forms to the State, so be sure to verify with carriers and within contracts.

Learn More

Rhode Island (RI)

Employers who sponsor self-insured plans must submit the requisite Forms 1095-C to the State. Fully insured plan carriers should report on an employer’s behalf. If they fail, however, employers must fulfill the reporting obligations. Employers must provide a Form 1095-C to necessary employees by March 2, and file with the State by March 31.

Learn More

Washington D.C.

D.C.’s requirements parallel federal filing. Employers may use Forms 1094/1095-C; Applicable Large Employers (ALEs) must submit these to the Office of Tax and Revenue by April 30th and to individuals by March 2.

Learn More

Vermont (VT)

No employer reporting requirements, even with a State individual mandate.

Learn More