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STATE ACA MANDATES
When passed IN 2010, the AFFORDABLE CARE ACT [ACA] required individual US citizens to purchase & maintain qualifying health insurance coverage – or face a federal penalty. By reducing these penalties to zero in 2019, the federal TAX CUTS & JOBS ACT [TCJA] effectively repealed this ACA individual mandate [as opposed to the ACA EMPLOYER MANDATE].
Eleven US states have since formally eliminated the original federal ACA mandate on individuals and implemented [or are in the process of implementing] their own STATE ACA MANDATES on individuals in its place.
It is under these eleven STATE ACA MANDATES that individual residents are now required to purchase & maintain health insurance – or face state penalties. This arrangement impacts ACA reporting for employers with employees in certain of those states.
Other than in Massachusetts, which has its own reporting system, these states typically piggyback on IRS FORMs 1095 & 1094 to gather information about the health coverage of their residents. This means that for certain states, in addition to ACA reporting to the IRS, APPLICABLE LARGE EMPLOYERS [ALEs] must also report health coverage to the relevant state governments for any full-time employees resident in those states.
NOTE: EMPLOYER VS EMPLOYEE LOCATION. The employer organization’s location is not the deciding factor concerning state ACA reporting obligations. The deciding factor is where the employee lives. This adds a layer of complexity for employers with employees who work remotely or commute to work from other states.
What follows is a CHECKLIST of the eleven mandating states, the ACA forms [where specified] to be distributed and filed, and the known deadlines.
| STATE | FORMS TO FILE | DEADLINES |
|---|---|---|
| CA |
IRS Employer Form 1094-C IRS Employee Forms 1095-B & C |
Distribution to employees: Jan 31.2025 State filing: March 31.2025 |
| CT | To date, no reporting specified | — |
| DC |
IRS Employer Form 1094-C IRS Employee Forms 1095-B & C |
Distribution to employees: March 03.2025 State filing: March 31.2025 [Likely dates subject to confirmation] |
| HI | To date, no reporting specified | — |
| MD | To date, no reporting specified | — |
| MA | MA 1099-HC Form |
Distribution to employees: Jan 31.2025 State filing: Also Jan 31.2025 |
| MN | To date, no reporting specified | — |
| NJ |
IRS Employer Form 1094-C IRS Employee Forms 1095-B & C |
Distribution to employees: March 03.2025 State filing: March 31.2025 |
| RI |
IRS Employer Form 1094-C IRS Employee Forms 1095-B & C |
Distribution to employees: March 03.2025 State filing: March 31.2025 [Likely dates subject to confirmation] |
| VT | See not below.* | — |
| WA | To date, no reporting specified | — |
*Vermont has retained the federal requirement for employers to distribute FORMS 1095; the federal deadlines apply of March 03.2025 for distribution]& March 31.2025 for filing.
This table was last updates Nov 12.2024.
If you have questions about STATE ACA MANDATES & REPORTING or any other aspect of ACA compliance, please contact BENEFITSCAPE, the leading ACA specialist.
BENEFITSCAPE provides best-in-class ACA services & FLAG & FIX REGTECH DIAGNOSTICS to 1000s of employers across all US states.