US Employers Now Have to Comply with ACA Reporting Requirements by Individual US State

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US Employers Now Have to Comply with ACA Reporting Requirements by Individual US StateJust when you thought ACA reporting for employers couldn’t get more complex… some states are now requiring ACA reporting at the state level as well.

What's the Situation?

With US employers finally used to the federal mandate requiring electronic submission of ACA forms to the IRS, some states are stepping up to create their own ACA state filing and reporting requirements with their own penalties for non-compliance. The expectation is that even if the federal reporting requirements are modified or eliminated, these states will uphold their own state requirements.

For the 2019 tax year, the only two “states” that require an employer filing are New Jersey and the District of Columbia. Massachusetts also has its own special guidance that has been in effect since 2006 but that guidance does not require employer reporting. California, Rhode Island, and Vermont have outlined plans starting as of the 2020 tax year. Connecticut, Hawaii, Maryland, Minnesota, and Washington have proposed bills to follow suit in reporting year 2020 and other states are considering this route as well.

Be aware that States are also establishing their own penalties for the individual mandate!

These state requirements can be challenging:

  • Each state is defining reportable employees differently.
  • Non-residents need to be excluded from the files to prevent submitting unnecessary (private!) information.
  • Each state determines how the data should be provided.
  • Each state will have different due dates for reporting.

What to watch out for with 2019 Reporting

New Jersey

If you have employees that have resided in New Jersey for at least 15 days in 2019 – regardless of where your organization is located - there is a NEW state level requirement to file ACA forms in New Jersey by March 31st!

Under New Jersey’s Health Insurance Market Preservation Act, insurers, employers, government agencies, multi-employer plans and other entities that provide health insurance must submit required information returns not just to the IRS but also to New Jersey, reporting on individuals’ health insurance coverage. The act imposes a mandate on both in-state and out-of-state employers who employed and provided minimal essential coverage to New Jersey residents during 2019. For purposes of the act, “residents” are both full and part-time residents where part-time is defined as anyone who resided in New Jersey for longer than 15 days any time during the calendar year.

Only electronic filing is supported and can be done using the Division of Revenue and Enterprise Services' (DORES) MFT SecureTransport service. There is no paper filing option available.

Currently, there is no employer penalty in place for not filing, but there most likely will be one after the state has finished reviewing, and it will be posted as soon as they finalize the details.

District of Columbia

DC‘s mandate is due June 30th, 2020 for the 2019 tax year. For subsequent years, the deadline will be moved up to April 30th. Filing will take place on the platform. Mailing in paper forms is also NOT an option. There is also no current employer penalty in place for not filing, but they are expected in the future.


Massachusetts has had a mandate for ACA since 2006, but the filing requirements are typically satisfied by insurance carriers, not employers. Employers with employees residing in the state will want to ensure that their filing obligations are met by insurance carriers.

2020 Reporting and Beyond

California‘s mandate isn’t in effect until 2020. The file submission format is expected to be like the one used by the IRS, but details haven’t been confirmed just yet.

Rhode Island has yet to disclose details of submission because the issue is still under legislative review. The state will probably have something ready for the 2020 tax year in 2021.

Vermont also has yet to disclose details of submission, and experts expect that they will also probably have something ready for the 2020 tax year.

Action Needed for ACA State Filing

ACA New Jersey State Filing

Good news – as an Integrity Data ACA customer, your ACA 1095-C forms for the 2019 filing year can now be e-filed on your behalf to the state of New Jersey, in accordance with their mandate, without the need to register with the state or meet additional burdensome requirements.

Our New Jersey State Filing Service will create a new file with your 1095-Cs, upload this file to the NJ system, and then accept the acknowledgement receipt – all on your behalf.

Please note that to be able to sign up for this service, you must also e-file your federal 1094-C through our solution.

To take advantage of this service – sign up here.

Rest assured that as states finalize their specifications, Integrity Data will be ready to address the requirements and help ensure employers are complying at the state level in the most efficient way possible.

Written by Integrity Data

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