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 By reducing these penalties to zero in 2019, the federal TAX CUTS & JOBS ACT [TCJA] effectively repealed this ACA individual mandate [as opposed to the ACA EMPLOYER MANDATE].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.