State Mandate ACA Reporting Requirements for Employers

Since the elimination of federal individual mandates under the Affordable Care Act (ACA) by Congress, 

some states have started to implement individual mandates at the state level. Employers who report the 

offered health coverage information to the IRS are now needed to report to those states about their 

residents’ health coverage information and furnish copies to their employees annually.

Residents (individuals) must purchase and maintain qualifying health insurance coverage or pay a state 

tax penalty for the below-mentioned states that have passed individual mandates.

California

California residents are required to receive health insurance coverage from their employers. Employers 

who offer Minimum Essential Coverage(MEC) to the employees are responsible for submitting a return 

to the state, stating that their employees (California residents) had qualified health insurance coverage 

throughout the year and furnishing the copies to the employees. 

Employees are supposed to receive copies of the forms from the employer to complete their individual 

tax returns.

Employers who employ California residents must file the same information found 

in Form 1095-B / Form 1095-C.

Deadline

The distribution of 1095 copies to the employees - January 31, 2021.

The reporting of Form 1095-B/C to the State by the employers - March 31, 2021.

To learn more about California ACA Reporting Requirements, please click here.

District of Columbia

As per the D.C. law, employers must provide “Minimum Essential Coverage” to the 

D.C residents and report it to the D.C. Office of Tax and Revenue (OTR) even 

offered “Minimum Essential Coverage” to at least one D.C. resident during the calendar year.

Employers must file the same information found in Form 1094 and 1095-B / 1095-C 

who employ D.C. residents.

Deadline

The Distribution of 1095 copies to the employees - March 02, 2021.

The reporting of Form 1095-B/C to the State by the employers - April 30, 2021.

To learn more about D.C. ACA Reporting Requirements, please click here.

Massachusetts

Employees (MA residents) must meet Minimum Creditable Coverage (MCC) 

throughout the tax year offered by the employers. At the same time, employers 

must also submit health coverage information to the state and furnish copies to employees.

To report the health coverage information to the state and distribute copies to 

employees, employers must use  Form MA 1099-HC.

Deadline

The Distribution of the copies of MA 1099-HC to the employees - January 31, 2021.

The reporting of Form MA 1099-HC  to the State by the employers - April 30, 2021.

To learn more about MA Form 1099-HC Reporting Requirements, please click here.

New Jersey

N.J. residents are supposed to receive Minimum Essential Coverage from 

 

the New Jersey employers or out-of-state employers. Those employers must 

 

also submit their offered health coverage information to the State of New Jersey 

 

through the MFT Secure transport service and distribute the copies to each primary enrollee.

To report the health coverage information to the state and distribute copies 

to the primary enrollee, employers must use Form 1094 and 1095-B / 1095-C.

Deadline

Distribution of the copies to the employees - March 02, 2021.

The reporting of Form 1095-B/C to the State by the employers - March 31, 2021.

To learn more about New Jersey Form 1095-B/C Reporting Requirements, please click here.

Rhode Island

Rhode Island residents must receive Minimum Creditable Coverage (MCC) 

throughout the tax year from the employers. At the same time, employers 

must also submit their offered health coverage to the state through the 

 Division of Taxation’s website, indicating that their residents had a 

MEC throughout the tax year and furnish the copies to the employees.

Employers must file the same information found in the 1094 and 1095-B / 1095-C 

who employ Rhode Island residents.

Deadline

Distribution of the copies to the employees - March 02, 2021.

The Reporting of form 1094 & 1095-B/C to the State by the employers - March 31, 2021.

To Learn More about Rhode Island Form 1095-B/C Reporting Requirements, please click here.

Vermont

Effective from January 1, 2020,  Vermont requires most of their Vermont 

residents over and above 18 to obtain health insurance coverage and submit 

their 2020 tax forms.

As of now, Vermont has not released any additional reporting requirements 

for employers. For any updated information, Click here to learn more about 

 Vermont ACA reporting requirements.

Few other states such as Connecticut, Hawaii, Maryland, Minnesota, and Washington  

are also considering individual mandates for their states. Learn More