The chart below summarizes the new state and local health coverage reporting requirements that apply to certain employers for health coverage they provided to their employees during the 2020 calendar year. These requirements are separate and in addition to any Form 1094 or 1095 health coverage reporting requirements employers may have.
| Locale | Who is Required to File | Who Must Be Reported | Forms | Furnishing Deadline | Filing Deadline | Filing Location | State Penalties | Helpful Links |
|---|---|---|---|---|---|---|---|---|
| CA | Self-insured Employers (Fully insured employers can rely on carrier) | Any covered CA resident employee (and covered spouse/ dependents) | 1095-B, 1095-C | 1/31/21 | 3/31/21 | Franchise Tax Board (electronic and paper filing available) | $50 per form for failure to file after 5/31/21 | https://www.ftb.ca.gov/file/business/report-mec-info/technical-specifications.html#publications |
| D.C. | Self-Insured Non-ALE & All ALEs | Any covered D.C. resident employee (and covered spouse/ dependents) | 1095-B, 1095-C | No separate requirement to furnish from federal requirements | 4/30/21 | Office of Tax Revenue (OTR) – electronic filing only through MyTax.DC.gov | None | https://otr.cfo.dc.gov/sites/default/files/dc/sites/otr/publication/attachments/FAQ%20reporting%20SRP%20Update.3.31.20.pdf |
| MA | Self-Insured Employers (unless TPA provides) | Any covered MA resident (and covered spouse/ dependents) | MA 1099-HC | 1/31/21 | 1/31/21 | Department of Revenue – electronic only through MassTaxConnect | $50 per form for failure to furnish | https://www.mass.gov/info-details/health-care-frequently-asked-questions-for-employershttps://www.mass.gov/service-details/health-care-reform-for-employers |
| NJ | Self-Insured Employers (Fully insured employers must report if carrier does not report) | Any covered NJ resident employee (and covered spouse /dependent) | 1095-B, 1095-C, or NJ-1095 | 3/2/21 | 3/31/21 | Division of Taxation – electronic filing only through Division of Revenue and Enterprise Services (DORES) | None | https://nj.gov/treasury/njhealthinsurancemandate/employers.shtml#:~:text=Insurers%20who%20provide%20coverage%20through,sent%20to%20each%20primary%20enrollee |
| RI | Self-insured Employers (Fully insured employers must report if carrier does not report) | Any covered RI resident employee (and covered spouse/ dependent) | 1095-B, 1095-C | 3/2/21 | 3/31/21 | Division of Taxation – electronic filing only through Division of Taxation portal | None | http://www.tax.ri.gov/healthcoveragemandate/index.php |