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State ACA Reporting Deadlines

The Affordable Care Act (ACA) created federal reporting requirements for employers and health plans. These reporting requirements provide the government with information to administer ACA mandates, like the large employer shared responsibility penalty and the individual mandate. The ACA’s individual mandate, updated January 1, 2019, requires individuals to have minimum essential health coverage (MEC) or qualify for a coverage exemption; however, they are no longer required to pay a penalty if they do not have MEC for part or all of the year.

The federal reporting deadlines require employers to furnish statements to individuals by March 2, 2023, and file returns with the IRS by February 28, 2023 (or March 31, 2023, if filing electronically).

State Reporting Requirements

Several states have enacted their own individual mandates, similar to the federal requirements under Internal Revenue Code Sections 6055 and 6056. States that have imposed health coverage reporting requirements to administer their individual mandates include California, the District of Columbia, Massachusetts, New Jersey, and Rhode Island.

California—imposes a MEC information reporting (MEC IR) requirement on every entity that provides MEC to an individual during a calendar year. Insurance providers must report health coverage information to the California Franchise Tax Board (FTB) each year by March 31, or face a penalty. Employers must report insurance information to FTB by March 31, only if their insurance provider does not report to FTB.

Additionally, San Francisco has its own requirements. The San Francisco Health Care Security Ordinance (HCSO) applies to employers with 20 or more employees and nonprofit employers with 50 or more employees working in San Francisco. HCSO requires covered employers to submit an Annual Reporting Form to the office of Labor Standards Enforcement (OLSE) annually by April 30.

District of Columbia—imposes a reporting requirement on every entity that provides MEC to an individual during a calendar year. To satisfy the requirement, applicable reporting entities must electronically file the federal forms 1094-C and 1095-C, or 1094-B and 1095-B, as necessary, through www.MyTax.DC.gov.

Massachusetts—has two health coverage reporting requirements that must be submitted each year.

  • HIRD form. Employers with six or more employees must submit the Health Insurance Responsibility Disclosure (HIRD) form by December 15. This responsibility is in addition to the ACA Code Section 6055 and 6056 requirements.
  • Form 1099-HC. Employers with an employer-sponsored health plan must provide Form 1099-HC by January 31 to each individual covered in the previous calendar year. Employers who do not comply will be subject to a penalty.

New Jersey—imposes the New Jersey Health Insurance Market Preservation Act, affecting every entity that provides MEC to an individual each calendar year. The deadline for filing and furnishing information generally follows the federal reporting requirement under Section 6055, including extension by the IRS.

It is important to note that reporting entities that use Form 1095-C must fully complete it or have Parts I and III completed or it will fail to meet any New Jersey filing requirement. Additionally, there is no paper filing option available, so insurers and employers must file Form 1095 online.

Rhode Island—in addition to the reporting requirement on every entity that provides MEC to an individual each calendar year, reporting entities must also provide a written statement to the primary insured containing specific information. The reporting deadline has been permanently extended to align with the ACA’s reporting deadlines. Additionally, files must be submitted on the Division of Taxation’s website.

Vermont—individuals must indicate on their state income tax returns whether they had MEC for each month of the year. If requested, individuals will also be required to submit a copy of the individual statement furnished to them by the provider of the MEC. Vermont will only impose its own provider reporting requirements if the federal requirement is suspended or eliminated for any taxable year.


If you have any questions regarding the state reporting requirements, please contact your dedicated Creative Benefits, Inc. team member.