California State ACA Filing Now Required Starting in Tax Year 2020

California State ACA filing is now required for ACA forms for Tax Year 2020. We know that new requirements can be tricky, so let us help you with your state and federal filing!

We have compiled a list of the the California state ACA filing requirements so you can be ready for January:

California State ACA Filing Requirements:

If you are an employer of a California resident, or if you provide Minimum Essential Coverage (MEC) to a California resident, including spouses and/or other dependents, you must report ACA data to the IRS and California’s Franchise Tax Board (FTB). See the guidance below to find out more.

California State ACA Filing Guidance

Forms 1094-C must be used to transmit Forms 1095-C to the IRS and the FTB. The same Forms 1094-C and 1095-C may be transmitted to the IRS, FTB, and furnished to the recipients.

Forms 1094-B must be used to transmit Forms 1095-B to the IRS and the FTB. The same Forms 1094-B and 1095-B may be transmitted to the IRS, FTB, and furnished to the recipients.

Fully Insured:

• When the insurer files Form 1095-C with the FTB, the employer offering the health coverage is not required to report to the FTB.
• According to the FTB, “if an employer is offering health coverage to employees other than a self-insured plan, such as an insured health plan or a multiemployer health plan, the issuer of the insurance or the sponsor of the plan are required to furnish the information to any enrolled employees.”

Self-Funded or Insurers:

• If you are an employer that offers health coverage through a self-insured plan, then you must report information about each enrolled individual using a federal Form 1095-C, Part III, for any employee (and other covered individuals).
• You must also complete a Form 1095-C for any employee that enrolls in the offered coverage, whether or not they were full-time for any month of the year.
• You do not need to submit Form 1095-C to the FTB for employees who were offered coverage, but chose not to enroll.
  
• If you are a health insurance issuer/carrier or government entity, you must file Forms 1095-B to report coverage.
• Employers must file Forms 1095-B to report employment-based MEC for employees except when health insurance issuers and carriers file federal Form 1095-B on the employers’ behalf.

Out of State Employers:

Out-of-State employers who employ California residents have the same filing requirements as in-State businesses. These requirements are not limited to businesses that withhold California payroll taxes.

If you are an out-of-State employer, you must ensure that CA receives any required 1095 document for each CA resident you employ.

Insurers, government agencies, multi-employer plans, and all others responsible for reporting Minimum Essential Coverage to California residents also must file the required information with the State.

What are the deadlines for California state ACA filings?

• The deadline to furnish forms to recipients is January 31.
  Please note: If you have already furnished a federal Form 1095-C to an individual, you do not need to provide an additional copy for CA purposes.
  
• The deadline to file your California ACA forms is March 31.
  Please note: If you need to file more than 250 forms, then you must file electronically. The FTB also encourages filing electronically for those with less than 250 forms.

What about other states?

Currently only a few states have ACA reporting deadlines. Check out their requirements here:

• District of Columbia
• New Jersey
• Rhode Island
• Vermont

Conclusion

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

Find more information about the California ACA filing program here:

• California FTB MEC Reporting Information
• California FTB Health Care Mandate Information

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