Massachusetts ACA Filing Requirements – TY 2023

Many states have adopted Individual Mandates. Massachusetts ACA filing is now required for certain employers and insurance providers.

Massachusetts Individual Mandate

For tax year 2023, along with federal requirements, Massachusetts has state regulations that require MA residents to have health coverage that meet certain standards. At the federal level, the coverage is known as Minimum Essential Coverage (MEC), but at the MA state level this is known as Minimum Creditable Coverage (MCC). This is the minimum level of benefits for taxpayers to be considered insured and not accrue penalties.

As with most Individual Mandates, this means that individuals without coverage may be subject to penalties at the state-level.

Massachusetts ACA Filing Requirements

Massachusetts ACA filing regulations require that employers that provide MCC to MA residents must submit documentation of this to the state. Employers must also furnish proof of coverage via Form 1099-HC to these residents. The form will show the months in which the individual was covered during the tax year.

  • For employers with fully-insured plans, most insurance providers will submit the filings on behalf of the employer. If the insurance provider fails to file, then this responsibility falls on the employer.
  • For employers with self-insured plans, the employer is responsible for submitting their Massachusetts ACA filing.

Important Note: It is the employer’s responsibility to ensure that their filings have been completed and submitted at the federal and state level.

How to file Massachusetts ACA filing with the state?

Employers must report all 1099-HC information through MassTaxConnect, through a Bulk XML upload, manual entry (one at a time), or through an Excel template. You can find more on the Massachusetts Health Care Reform page.

What are the deadlines for Massachusetts ACA filings?

Traditionally, the deadlines for Massachusetts ACA filings are as follows:

  • Furnish forms to recipients – January 31
  • File your forms with the state electronically – March 31
  • Submitting a paper filing to the MA Department of Revenue is not permitted.


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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