Employers ringing in the New Year should remember that several states’ have additional ACA filing and furnishing obligations that must be completed for the 2021tax year.
To help you get a handle on the many state ACA deadlines, we’ve listed the due dates and reporting requirements for the 2021 tax year, to be filed in 2022, below.
California
Self-funded employers and health insurance carriers in California must furnish healthcare information to their employees and their dependents by January 31, 2022. The instructions state that employers should not submit 1095-C forms for employees who received an offer of coverage but did not enroll.
The ACA healthcare information must be filed by March 31, 2022, though, like last year, no penalty will be assessed for employers that file ACA information with the state by May 2022. Both paper mailing and electronic filing options are available.
Employers should file their ACA information with the California Franchise Tax Board (FTB). Failing to meet the requirement could subject your organization to a $50 penalty per individual provided coverage.
New Jersey
If your organization has operations in the state of New Jersey and you’re an Applicable Large Employer (ALE), then you will need to furnish 1095-C forms to your ACA full-time employees by March 2, 2022, for the 2021 tax year. The ACA state deadline for filing with the state of New Jersey is March 31, 2022.
Rhode Island
Rhode Island employers must furnish applicable healthcare statements to ACA full-time employees by January 31, 2022, for the 2021 tax year. The ACA state filing deadline for Rhode Island employers is March 31, 2022. Employers must file the applicable ACA healthcare information for the 2021 tax year to the state’s Division of Taxation.
Vermont
Despite the state’s Individual Mandate requiring residents to obtain coverage, there are still no additional ACA reporting requirements for employers.
Washington D.C.
Employers with operations in D.C. must furnish the 1095-C to applicable ACA full-time employees by March 2, 2022, for the 2021 tax year. The reporting deadline to local government agencies must be completed by April 30, 2022, which is 30 days after the federal due date.
The District of Columbia’s reporting law applies to employers that provide Minimum Essential coverage to individuals. Employers should submit their healthcare information to the region’s Office of Tax and Revenue electronically through MyTaxDC. Paper filings will not be accepted.
Federal
State reporting and furnishing requirements are in addition to the federal, which have been in place since 2015. The federal ACA reporting and furnishing requirements have their own nuances as well as separate deadlines.
If you have operations in multiple states and need assistance meeting the various ACA reporting requirements, contact us to learn about our all-inclusive, comprehensive ACA Complete solution. Already have a handle of federal ACA reporting? We offer stand-alone state ACA reporting solutions as well.
As a reminder, ACA reporting requirements are a function of the healthcare law’s Employer Mandate, which requires ALEs, or employers with 50 or more full-time employees and full-time equivalent employees to:
- Offer Minimum Essential Coverage (MEC) to at least 95% of their full-time employees (and their dependents) whereby such coverage meets Minimum Value (MV); and
- Ensure that the coverage for the full-time employee is affordable based on one of the IRS-approved methods for calculating affordability.
Need assistance populating your respective 1095-C forms for the 2021 tax year? Download the Employer’s Guide to Coding ACA Form 1095-C below.
