Federal Affordable Care Act (ACA) requirements remain in place for employers regarding the employer mandate and associated IRS reporting requirements. In addition to these federal requirements, some states are starting to enact and implement their own versions of the ACA’s individual mandate with associated employer reporting requirements.
Effective January 1, 2019, taxpayers in both the District of Columbia (D.C.) and New Jersey are required to maintain minimum essential health coverage or potentially pay a penalty. In both cases, employer reporting of health coverage information (IRS Forms 1094-C and 1095-C) is required to assist the state in enforcing the individual health coverage mandates.
What this Means for You
Our service and product teams are hard at work defining our first release of our State Reporting component based upon the requirements the states have provided thus far. Since the ACA's employer mandate and all associated informational reporting are still in effect nationwide, the data necessary for any separate state-based informational reporting is likely part of your existing data as an ADP Workforce Now Essential ACA Client.
At this time, it has been determined that:
· Data will be utilized from the same Forms 1094-C/1095-C that you use for federal reporting with the IRS.
· Data utilized throughout the year for ACA IRS reporting will provide the ability to identify employees that lived in these areas (New Jersey and D.C.) at any time during the year.
· Due dates for 2019 state reporting: New Jersey is due in March 2020, Washington D.C is due June 2020.
· During this first transmission year, we plan to define additional functionality to include for the 2020 reporting year as additional states (currently California and Rhode Island) come online with their individual regulation and reporting requirements.
· Should ADP find that additional data or activities are required for the State Filings, know that your ADP
Comprehensive Services ACA Center of Excellence will alert you and guide you through any necessary steps.
For more information on each state and their reporting requirements, please reference ADP’s Eye on Washington article from August 19, 2019.