Important 2024 ACA State Requirements (TY 2023)

Affordable Care Act (ACA) reporting can be a challenging process on its own, but with the addition of ACA State Requirements and Individual Mandates, the ACA filing process has only grown in complexity.

What is an Individual Mandate?

The Individual Mandate is an ACA provision that requires individuals to purchase certain coverage unless they’re eligible for an exemption. If they aren’t eligible for an exemption and do not purchase coverage, they may be subject to a tax penalty.

The Individual Mandate is technically still in effect at the federal level, but there’s no longer a tax penalty to enforce the mandate. Due to this, many states have opted to adopt versions of this requirement.

How do ACA state Individual Mandates affect employers?

Generally, employers that offer Minimum Essential Coverage (MEC) to employees will need to file their ACA information with the state tax department. Failing to fulfill ACA state-level requirements could result in penalties for the employer.

Which states have Individual Mandates?

As of today, California, Massachusetts, New Jersey, Rhode Island, Vermont and the District of Columbia have Individual Mandates in place.

ACA State Requirements and Deadlines

California

• Employers must use the appropriate IRS forms to report health insurance information with the CA Franchise Tax Board (FTB).
• Self-funded employers must report employee (and their dependents) health insurance coverage information to the state.
• Data may be electronically filed via CA’s Minimum Essential Coverage Information Reporting (MEC IR) program.
• The deadlines are traditionally as follows:
  • Furnish forms – January 31
  • File with the state – March 31

District of Columbia

• All applicable entities that provide MEC to an individual during a calendar year must submit a filing regarding the coverage to their Office of Tax and Revenue (OTR).
• All filings must be filed electronically through MyTaxDC; paper filings will not be accepted.
• Deadline to file with the district – 30 days after the federal ACA e-file deadline. 

Massachusetts

• Massachusetts state filings do not need to contain the same employee-level details like federal filings. Because of this, they are typically completed by insurance providers on behalf of the employer.
  • Important Note: It is the employer’s responsibility to ensure that their filings have been completed.
• In addition, MA employers must issue Form 1099-HC to their employees and report that information with the MA Department of Revenue.
• The deadlines are traditionally as follows:
  • Furnish forms – January 31
  • File with the state – March 31
• Note: If any due date falls on a weekend or legal holiday, the filing is considered timely filed/furnished on the next business day.

New Jersey

• All employers must use the appropriate IRS forms to report health insurance information with the NJ Department of Treasury.
• Employers must also furnish these forms to each primary enrollee.
• Filings may be submitted through the NJ’s Division of Revenue and Enterprise Services (DORES) MFT SecureTransport (Axway) Service.
• The deadlines are traditionally as follows:
  • Furnish forms – March 2
  • File with the state – April 2

Rhode Island

• Employers must offer MEC to residents and must submit state-level filings to the RI Division of Taxation.
• Employers must also furnish forms to each primary enrollee.
• The deadline is traditionally March 31

Read more about Rhode Island ACA Filing Requirements here.

Vermont

• Currently, there are no additional requirements for employers, but there will be ACA state requirements if federal ACA reporting requirements are eradicated. 

Conclusion

Employers must keep these ACA state requirements in mind when completing their filings. It is imperative that employers ensure that these state requirements and federal requirements are met prior to each applicable deadline.

Once you have submitted your ACA filings federally and to the applicable states, have received an “accepted” status, and have furnished employee copies, then it sounds like you have fulfilled all of your ACA requirements.

As the landscape of ACA compliance, 1099 filing, and W2 filing continues to grow in complexity, it is imperative that filers stay on top of IRS updates and deadlines. Be sure to review the upcoming deadlines here:

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