ACA TY24: State Mandates Guide & Checklist

Poster map of United States of America with state names. Print map of USA for t-shirt, poster or geographic themes. Hand-drawn colorful map with states. Vector Illustration

When passed, the Affordable Care Act [ACA] required individuals 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 By reducing these penalties to zero in 2019, the federal Tax Cuts & Jobs Act [TCJA] effectively repealed the ACA individual mandate [as distinct from the ACA employer mandate].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 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 gather information about the health coverage by piggybacking on IRS FORMs 1095 & 1094. This means that for certain states, in addition to ACA reporting to the IRS, ALEs must also report health coverage to 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.

 

Click here for a CHECKLIST of the eleven mandating states, the ACA forms [where specified] to be distributed and filed, and the relevant deadlines.

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.

News & Latest Posts

PCORI Fees Due July 31. Download Our Employer Guide

July 9, 2026

PCORI fees are federal taxes mandated by the Affordable Care Act and…

PFML Complexities Demand Better Connected Data

June 17, 2026

When employers think about Paid Family and Medical Leave (PFML), they typically…

Trump Accounts: What Employers Need to Know

July 8, 2026

Starting July 2026, employers can make voluntary, tax-free contributions of up to…

Increased Federal Scrutiny for ACA Eligibility

May 29, 2026

On May 15, the Centers for Medicare & Medicaid Services [CMS] issued…

AI & Regtech for Employee Benefits [Part 2/3]

June 1, 2026

The AI revolution is fueling far-reaching business transformation. These ‘AI & RegTech’…

Updates: Massachusetts PFML Highlights Compliance Challenges

July 1, 2026

State-mandated benefit programs, including Paid Family and Medical Leave [PFML], place a…