The Affordable Care Act (ACA) state reporting requirements are critical for employers, especially those operating in states with individual mandates. Compliance extends beyond federal obligations — employers must also adhere to specific state rules to avoid penalties. This guide outlines the key reporting requirements for states with their own mandates, helping employers navigate this complex landscape.
As ACA reporting evolves, several states have established individual mandates requiring residents to maintain health coverage. Employers in these states face additional obligations, including filing specific forms with state agencies and providing documentation to employees.
The Importance of Compliance
Failing to meet state ACA reporting requirements can result in fines, penalties, and increased scrutiny. Staying informed on state-specific deadlines and mandates is essential to avoiding compliance risks.
State-Specific ACA Reporting Requirements
California
California requires employers to report health insurance information directly to the Franchise Tax Board (FTB). Self-funded employers must include details about employee and dependent health coverage. Reporting can be completed electronically via the state’s Minimum Essential Coverage Information Reporting (MEC IR) program.
Key deadlines:
- Employee forms: Furnish by January 31.
- State filing: Submit by March 31.
District of Columbia
In the District of Columbia, any entity providing Minimum Essential Coverage (MEC) to an individual must report the coverage to the Office of Tax and Revenue (OTR). Filings are submitted exclusively through the MyTaxDC portal; paper submissions are not accepted.
Key deadline:
- Submit filings to the district 30 days after the federal ACA e-file deadline.
Massachusetts
Massachusetts has streamlined its ACA reporting process. State filings typically omit detailed employee-level information and are often completed by insurance providers on behalf of the employer. However, employers are responsible for ensuring these filings are submitted.
Additionally, Massachusetts employers must issue Form 1099-HC to employees and report this information to the Department of Revenue.
Key deadlines:
- Employee forms: Furnish by January 31.
- State filing: Submit by March 31.
Note: If a due date falls on a weekend or holiday, the filing deadline moves to the next business day.
New Jersey
New Jersey requires all employers to submit health insurance reporting to the Department of Treasury using the appropriate IRS forms. Employers must also furnish these forms to primary enrollees. Submissions are handled electronically through the Division of Revenue and Enterprise Services (DORES) MFT SecureTransport service.
Key deadlines:
- Employee forms: Furnish by March 2.
- State filing: Submit by April 2.
Rhode Island
Employers providing MEC to Rhode Island residents must submit state-level filings to the Division of Taxation and furnish forms to primary enrollees.
Key deadlines:
- Employee forms and state filing: Submit by March 31.
Vermont
Currently, Vermont does not impose additional ACA reporting requirements. However, if federal ACA mandates are repealed, Vermont may introduce its own state-level obligations. Employers should monitor any regulatory updates to ensure they’re prepared for potential changes.
Managing ACA Reporting Obligations
As ACA reporting evolves, staying informed about state-specific mandates is essential for compliance. Employers should plan ahead, verify data accuracy, and utilize electronic filing systems where required. By meeting these state-level requirements, you can avoid penalties and maintain smooth operations during reporting season.
The information contained in this article is provided for informational purposes only and should not be construed as legal advice on any subject matter. The reader should not act or refrain from acting on the basis of any content included in this article without seeking tax, legal, or other professional advice. The contents of this article contain general information and may not reflect current legal developments or address the reader’s situation. ebm disclaims all liability for actions the reader takes or fails to take based on any content within this article.
