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Washington DC is one of several jurisdictions to have implemented an individual mandate in the wake of Congress zeroing out the federal ACA penalty for individuals who do not have coverage. This state-level mandate mirrors the ACA’s individual mandate, requiring employers and plan sponsors with “at least 50 full-time employees, including at least one employee who was a District resident” to “maintain minimal essential health care coverage, qualify for a coverage exemption, or pay a tax penalty.”
The DC law requires every “applicable entity that provides Minimum Essential Coverage to an individual during a calendar year” to submit an information return regarding such coverage to the Office of Tax and Revenue (OTR). It also requires the applicable entity to submit a statement about the individual’s type of coverage. These filing requirements, while similar to Federal filing requirements under the ACA, are not the same. All information returns are required by OTR to be filed electronically through MyTaxDC, as paper filings will not be accepted. The new tax guidance requirements for annual reports are due beginning June 30, 2020.
All digital files submitted through the DC system must be in a pipe delimited text (.txt) format. There is a cap on the size of the file submission. Files 250MB or larger must be sent as multiple submissions. Any files that are 250MB or larger will be rejected. Employers will be required to use a naming convention such as ABCCo1094BC.txt, ABCCo1095BC.txt. There are no specific restrictions on the naming convention. Submissions cannot use any special characters in text fields such as commas in the string fields unless they are nested in quotes (“). All duplicate files will be rejected.
Testing of the DC filing system was closed June 1, 2020. While not required, testing gave employers and vendors the opportunity to preview and correct any filing issues that may occur.
Employers should seek out expert ACA compliance consultants to prepare for increased ACA compliance and statewide Individual Mandate filing requirements. If you need assistance with D.C. 1094/1095 filing, Trusaic is still accepting clients until June 23rd, 2020.
