Satisfy ACA State Filing and Furnishing Requirements

Currently, five states (plus D.C.) have enacted Individual Mandates that require employers to report health coverage data directly to state revenue departments. You must file if you have employees who are residents of:

• California: Requires filing (uses federal 1094/1095-C data).
• New Jersey: Requires filing (uses federal 1094/1095-C data).
• Rhode Island: Requires filing (uses federal 1094/1095-C data).
• Washington D.C.: Requires filing (uses federal 1094/1095-C data).
• Massachusetts: Requires filing a specific state form (Form 1099-HC).

How Trusaic Helps: We support full state filing compliance for all active jurisdictions. Our software audits your workforce’s residency history to identify exactly which employees trigger a state filing. We then generate the required file formats and transmit them securely to each state agency with the exception of Massachusetts..

No, we do not support state filing for Massachusetts. It is the only state not covered by our filing service.

No. State deadlines can differ from federal ones, creating a compliance trap for employers who assume the federal schedule applies everywhere.

• Federal Schedule:
  • Furnish to Employees: March 2 (or upon request)
  • File with IRS: March 31.
• State Exceptions:
  • California: March 31, 2026 (The California Franchise Tax Board provides an automatic, penalty-free extension to file until May 31, 2026)\
  • Massachusetts: The state filing deadline to electronically submit Form MA 1099-HC through the MassTaxConnect portal is March 31, 2026
  • New Jersey: March 31, 2026
  • Rhode Island: March 31, 2026
  • Washington D.C.: April 30, 2026

Warning: If you wait until the federal March 2 deadline to print your forms, you will be late for every employee residing in California, Rhode Island, or Massachusetts, potentially triggering state-level penalties.

How Trusaic Helps: Our system automatically manages these staggered deadlines. We identify and prioritize the fulfillment for employees in early-deadline states (like CA) to ensure they are mailed by January 31, while allowing you to utilize the full federal window for the rest of your population.

Yes. We offer ACA State Filing as a standalone solution or as an add-on to ACA Essential. It could be used as a standalone service for organizations that handle their federal IRS reporting in-house (or through another payroll vendor) but lack the technical capability to transmit to state portals. This is a common scenario for employers using payroll platforms that support federal 1095-C filing but have not yet upgraded to support the unique XML schemas required by states like California or New Jersey.

How Trusaic Helps: You do not need to create new data files. You can simply securely upload your finalized federal data (PDFs or standard data files) to us. We will then:

1. • Convert the data into the specific XML formats required by CA, NJ, RI, and D.C.
   • Transmit the files to the respective state revenue departments.
   • Manage the status updates until the file is “Accepted” by the state.

Yes. State ACA reporting obligations are based on the tax residency of the employee, not the physical location of the employer. If you employ a remote worker who resides in a state with an individual mandate (like California, New Jersey, Rhode Island (employee also has to be enrolled in self funded coverage), or D.C.), you are legally required to file with that state’s revenue department for that specific employee.

Example: If your company is headquartered in Texas (which has no state mandate) but you have a single full-time remote employee living in California who is enrolled in a self funded health plan, you must file with the California Franchise Tax Board for that one employee.

How Trusaic Helps: You don’t need to manually segregate your workforce or research state laws. Our system ingests your entire employee census and automatically filters by state residency — even tracking mid-year moves between states—to ensure you file strictly for the employees who trigger a state mandate, without over-reporting.

No, employers cannot simply upload your federal IRS file to a state portal. While the data (employee names, coverage codes) is identical, the electronic file structure (XML Schema) and transmission protocols differ for each state.

• Schema Mismatches: States often require unique manifest headers or state-specific coding that is not present in the federal XML file.
• Transmission Systems: Each state uses a unique intake system — such as California’s MEC IR or New Jersey’s MFT SecureTransport — that will immediately reject a standard federal file format.

How Trusaic Helps: We eliminate the need for multiple vendors or custom coding. We take your approved federal data and automatically reformat it into the distinct file types required by CA, NJ, RI, and D.C.. We handle the secure transmission to each individual state agency, managing any Accepted with Errors status updates so you don’t have to decipher XML rejection codes.