As more states pass their own individual mandate, many now have their own version of employer reporting requirement.  Does your Company have to Comply with an ACA State Individual Mandate?

Although the ACA individual mandate is gone at the federal level; many states have begun to implement their own ACA state individual mandates, which require residents to purchase and maintain qualifying health coverage or face a state tax penalty.  We anticipate that more states will follow suit in pursuing ACA state individual mandates. So, employers should anticipate some reporting changes at the state level. Now is the time to determine if you have employees who reside in a state with an ACA individual mandate.

As a disclaimer, we (Selerix) are not consultants or legal counsel and can't dictate employers' decisions..  We can only offer our understanding of the expectation related to the state-level requirements outlined by individuals’ states.  That said, we always advise employers to seek guidance from their advisor and/or legal counsel.  
 
Which states are affected by the ACA state individual mandate?
To date, six states have passed individual mandates with additional states on the horizon for implementing their own ACA state individual mandates.   
  • California – Effective January 1, 2020
  • District of Columbia
  • Massachusetts
  • New Jersey
  • Rhode Island – Effective January 1, 2020
  • Vermont – Effective in 2020
Below is what we know so far and will continue to provide updates as more information is released.
California Individual Mandate Guide
Important dates
Employers are required to file annually by March 31. For the 2023 tax year, the due date was extended to April 1, 2024. The employee form postmark deadline is January 31, 2024.

District of Columbia Individual Mandate Guide
Important dates
Employers are required to file annually by March 31. For the 2023 tax year, the due date was extended to April 1, 2024. The employee form postmark deadline is March 4, 2024.

Massachusetts Individual Mandate Guide
Important dates
Employers are required to report annually using the 1099-HC. For the 2023 tax year, the due date is January 31, 2024. The employee form postmark deadline is January 31, 2024.

Most insurance companies issue the forms on the employers’ behalf and send the state a reporting listing all the Form MA 1099-HC they issued.

New Jersey Individual Mandate Guide
Important dates
Employers are required to report annually by March 31. The employee form postmark deadline is March 4, 2024.

Rhode Island Individual Mandate Guide
Important dates
Employers are required to report annually by March 31. The employee form postmark deadline is March 4, 2024. 

Vermont Individual Mandate Guide
Providers of MEC will only be required to report information in the event that the federal reporting requirement under Section 6055 is suspended or eliminated for the taxable year.