New DC ACA Health Mandate State Reporting – 2019

It is important to realize, the new DC ACA health mandate for residents is here! 1094/1095B and 1094/1095C series forms requires submission to the state. Brand new state policies does not signify uncertainty. Below are some common questions and concerns employers have.

New DC ACA health mandate?

The DC ACA health mandate requires all DC residents have a minimum essential health care coverage. Taking affect in 2019, tax year 2019 is the first time employers must take this into consideration.

What form type requires submission?

Starting tax year 2019, District of Columbia requires employers to submit a state filing for 1094/1095B and 1094/1095C series forms. Below are images of Form 1094-B and 1094-C, the transmittal forms for ACA filing for the IRS.

Image of Form 1094-b
IRS Form 1094-B, Transmittal of Health Coverage Information Returns
Image of Form 1094-C, Part I
Image of Form 1094-C, Part I

Specifications for employers to file?

The DC ACA health mandate requires employers who cover more than 50 employees with at least one individual residing in DC, must file submission. Employers do not meet specifications if, the employee commutes to DC, but does not reside there. Therefore, no submission required.

When is the deadline to file for DC ACA health mandate?

The first submission deadline for employers to file is June 30th 2020.

Can employers send the same file to federal and state?

No, the IRS and District of Columbia have different formats for their filings. Even though the contents of the file are the same, the District of Columbia has adapted their own format for state E-filing which differs from the file format the IRS accepts. After all, this is a completely new process and quite difficult to interpret the specifications of their file format and rules. Learn more about the federal filing requirements here.

Complexity of DC ACA health mandate format.

As previously mentioned, the District of Columbia has decided to come up with their own format for accepting state E-filing. Unfortunately, the format is very different and the complexity is much higher than the standard IRS file. Included is a downloadable excel template from DC. In short, why should employers be tasked with learning these extensive new rules? Below are some key points to take into consideration.

  • Complicated file format
  • Adapted pipe delimited file
  • Lengthy data entries for employees with various covered individuals
  • Over 600 fields of required data for each employee
  • Brand new state specific rules
  • Different format and rules than IRS

What about other states?

Only a couple of states have ACA state requirements. They are the District of Columbia and New Jersey for tax year 2019.


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.

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.

If you’re looking for more information on ACA Summary Forms 1094-B and 1094-B to determine which type you need to file, download our Understanding ACA Summary Forms Guide here:

BoomTax, The Boom Post, and its affiliates do not provide tax, legal or accounting advice. This material has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. You should consult your own tax, legal and accounting advisors prior to engaging in any transaction.

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