State Reporting Overview

ACA Deadlines For TY 2021 (Federal and State);

NOTE: Based on recent IRS Extensions, these values will be Updated when States announce their Filing Deadlines.

  Jurisdiction   Form to Employee   eFiled to Jurisdiction
 Federal IRS  March 2, 2022 March 31, 2022
 California January 31, 2021 * March 31, 2021 **
 Dist of Columbia March 2, 2021 April 30, 2021
 New Jersey March 2, 2021 March 31, 2021
 Rhode Island  March 2, 2021 March 31, 2021




* California Franchise Tax Board (FTB) advises that they do not have any statutory authority to extend the 1/31/2021 date for providing Form 1095 to employees (like the  federal government did by extending the date to March 2, 2021).  The date to furnish to individuals remains 1/31/2021.  However, there is no California penalty for providing forms to individuals past this 01/31/2021 date.   

Compliance TIP:  Because FTB cannot change the date to provide Form 1095 from January 31, 2021 they have indicated there is no California penalty for missing this date. Even though employers face no penalty, they should endeavor to provide Form1095 to employees as soon as possible, closest to January 31, 2021. 

** California Franchise Tax Board (FTB) advises the date for information returns to be made to FTB was March 31, 2021 (original)  and currently is May 31, 2021 by virtue of the automatic 2-month extension passed in the FTB regulatory package.


Washington, DC  The reporting requirement for DC encompasses any employee for whom the employer withholds DC taxes, or any employee who has a DC mailing address, even if the employer doesn’t withhold and report DC taxes.

Forms to be distributed to Employee March 2, 2021
Forms to be filed with State Authority April 30,2021


New Jersey  Beginning in 2020, New Jersey will require employers to report prior-year health coverage information for covered employees and their dependents residing in the state. Reporting guidance specifies that employers and other MEC providers must transmit health coverage returns for the 2020 tax year through New Jersey’s e-file system for W-2 forms by March 31,2021. Employers that furnish covered employees with MEC notices for federal purposes do not have to provide duplicate notices. The returns must contain the information required for IRS Forms 1094-C and 1095-C. Companies are encouraged to send only New Jersey residents’ data, but the state will accept the same 1094/1095 files sent to the IRS — even if they include data for out-of-state residents.

Forms to be distributed to Employee March 2, 2021
Forms to be filed with State Authority March 31, 2021

Massachusetts  At the end of each coverage year, employers that provide minimum creditable coverage  (MCC) or their vendors must distribute Form MA 1099-HC to covered Massachusetts residents  and report this information to the state Department of Revenue (DOR) by January 31.Most employers rely on their insurance vendors or Third-Party Administrators to determine MCC status, distribute the forms and file the DOR report

Form 1099HC to be distributed to Employee January 31, 2021
Form 1099HC to be filed with MassTax Connect March 31, 2021

California  Beginning Jan. 1, 2020, California’s new mandate (2019 Ch. 38, SB 78) will require state residents to maintain Minimum Essential Coverage (MEC) for themselves and their dependents. Self-insured plan sponsors, health insurers and other entities that provide MEC to residents  must file coverage reports with the California Franchise Tax Board (FTB) by March 31 after the coverage year has ended. The FTB will develop reporting forms, but currently, the same information reported to IRS under IRC § 6055 will suffice for California reporting.

Forms to be distributed to Employee Suggested: January 31,2021  no penalty for late delivery
Forms to be filed with CA FTB March 31, 2021 Extended to 5/31 with no penalty.


Rhode Island  Rhode Island’s Market Stability and Reinsurance Act (2019 Ch. 88, HB 5151 Art. 11) reinstates the individual coverage mandate for state residents, beginning in 2020. The state law closely follows the ACA mandate in its original form, including the definition of MEC and penalty calculations. While it has not been confirmed, the IRS coverage-reporting forms may suffice for Rhode Island’s reports that include:  Name, address, and TIN of the primary insured and the name and TIN of each other individual obtaining coverage under the policy; - The dates during which the individual was covered under minimum essential coverage during the calendar year; and - Such other information that the tax administrator may require

Forms to be distributed to Employee March 2, 2021
Forms to be filed with State Authority March 31, 2021


Vermont  Amendments to Vermont’s individual health coverage mandate (2019 Act 63, HB 524) require residents to self-report compliance beginning in 2020. Residents filing individual income tax returns will indicate if they had MEC during the tax year and, if requested by the state, will have to submit their IRS Forms 1095-B and 1095-C as proof. Vermont doesn’t require employer reporting unless the ACA mandate (IRC § 6055) for MEC providers to furnish a statement to covered individuals is suspended or eliminated.

State Mandate eFiling Services

In December 2017 (effective January 1, 2019), Congress repealed the financial penalties for individuals not having health insurance, but the requirement to  have health insurance is still in place. Since then, some states have turned to state individual mandates in order to keep their healthcare marketplaces stable and generate additional revenue. 

Which states have individual healthcare mandates?

Currently, Massachusetts, California, the District of Columbia, New Jersey, Rhode Island, and Vermont have passed state individual mandates. With each state passing its own individual mandate, it makes it difficult for companies to keep up with all the different regulations and reporting requirements. Essentially, even if you have one employee filing taxes in one of these states, your company must comply with that state’s individual mandate. This means companies will not only have to be ACA complaint at the federal level, but also at the individual state levels.

BenefitScape has obtained all of the various credentials and testing to be able to send your Federal XML file to those states currently requiring filing for TaxYear 2019 and 2020.  We would be pleased to work with you to accomplish the eFiling the various state authorities. 

BenefitScape State Mandate eFiling Service

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Have a Question or Need a Quote?

Federal ACA Compliance and Reporting and State Mandate e-filing is very complex. We have found that a short phone call is often the best way to see what we can do for you and your company.

Please fill out the form to the right and submit. If you have a specific concern let us know. We will come back to you via email with a few times for a call to discuss your situation.