The Internal Revenue Service ("IRS") has permanently extended the deadline to March 2nd each year for furnishing Affordable Care Act ("ACA") Forms 1095-C (or 1095-B) to full-time employees and other individuals to demonstrate proof of health insurance coverage for each month of the calendar year ("CY"). Form 1094-C and all Forms 1095-C for the prior CY must be furnished to the IRS by March 31st each year (unless eligible for paper filing, then by February 28).
For ACA compliance, the IRS permits insurance carriers to post information on their website how plan members may access and receive a copy of the Form 1095-B in lieu of automatically mailing (or electronically issuing) statements to plan members. Insurance carriers must still prepare Forms 1095-B and file these forms with the IRS no later than March 31, 2023, for the calendar year 2022 reporting requirements.
Currently five states (California, Massachusetts, New Jersey, Rhode Island, and Vermont) and the District of Columbia have enacted individual health insurance mandates with their own requirements for:
These requirements and deadlines may (or may not) align with the federal requirements. The following chart summarizes important deadlines related to 2022 state individual mandate reporting.
|State||Deadline to Furnish Statements to Employee Residents||Deadline to File Statements with State Agency|
|California||January 31, 2023. However, no penalty is imposed for failing to furnish by this deadline.||March 31, 2023. No penalties will be assessed if filed by May 31, 2023.|
|District of Columbia||March 2, 2023||April 30, 2023 (30 days after federal deadline)|
|Massachusetts||January 31, 2023||January 31, 2023|
|New Jersey||March 2, 2023||March 31, 2023|
|Rhode Island||March 2, 2023||March 31, 2023|
Important issues to consider regarding furnishing and issuing state-level MEC information are as follows:
Employers with employees and/or plan members residing in a state (and/or the District of Columbia) with individual mandate reporting requirements should confirm state individual mandate reporting requirements with their carrier, TPA or ACA vendor to ensure federal as well as state-level reporting obligations will be met.
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