Due to the new 1095-C form furnishing rules, employers are no longer required to automatically furnish Form 1095-C to every employee. Instead, they must make it available upon request and maintain a public notice of that right through Oct. 15 of the following year.
However, employers still must adhere to state ACA mandates. California, New Jersey, and Rhode Island maintain their own ACA furnishing requirements that remain unaffected by the federal change.
Failing to distribute 1095-C forms to employees in those states could lead to penalties, even if you’re compliant at the federal level.
Federal vs. State ACA Furnishing Rules
At the federal level, the IRS now allows employers to post a notice on their website informing employees of their right to request Form 1095-C, rather than automatically furnishing it. This change was meant to reduce administrative burden.
But states with their own ACA individual mandates have not uniformly adopted this approach. In fact, only one jurisdiction — Washington, D.C. — has explicitly stated that compliance with the federal furnishing rules satisfies its local requirement.
That means employers with employees residing in California, New Jersey, or Rhode Island who are enrolled in a self-funded health plan, must still directly furnish 1095-C forms to those states, regardless of the new federal rule.
State-by-State ACA Furnishing Requirements
California
- Furnishing: Employers must continue to furnish 1095-C forms to employees by Jan. 31 of the year following coverage. The California Franchise Tax board does not impose a penalty for failure to provide information statements to individuals by Jan. 31.
- Filing: Employers with California residents must also file with the California Franchise Tax Board by March 31. Entities have an automatic extension until May 31 to file the federal forms with FTB. After that date, FTB may assess a penalty of $50 per individual who was provided health coverage.
- Notes: California has not updated their instructions to specifically recognize the federal “upon request” furnishing method — employees must still receive forms directly.
New Jersey
- Furnishing: Employers must distribute 1095-C forms to all New Jersey residents by March 2.
- Filing: Forms must also be filed electronically with the New Jersey Division of Taxation by March 31.
- Notes: New Jersey’s individual mandate remains fully in effect, and furnishing compliance continues to be required annually.
Rhode Island
- Furnishing: 1095-C forms must be provided to employees by March 2.
- Filing: Employers must file with the Rhode Island Division of Taxation by March 31.
- Notes: Rhode Island follows similar timelines as the federal IRS deadlines but has not aligned its furnishing standards with the new federal rule.
Washington D.C.
- Furnishing: D.C. explicitly accepts compliance with the federal furnishing standard as satisfying its local requirement.
- Filing: ACA forms must still be filed electronically with the D.C. Office of Tax and Revenue by April 30.
- Notes: Employers that meet federal furnishing and filing standards automatically meet D.C.’s obligations.
Massachusetts
- Unlike other states, Massachusetts requires employers to file a state-specific form called Form MA 1099-HC. Note that this is the only form that Trusaic does not support.
- Furnishing: 1095-C forms must be provided to employees by January 31st. Failure to do so is punishable by a penalty of $50 per individual to which the failure relates, not to exceed $50,000 per year per violator.
- Filing: Employers must file with the Massachusetts Department of Revenue by March 31.
Why This Matters for Multi-State Employers
For organizations with employees in multiple states, compliance is not one-size-fits-all.
If a single employee who is enrolled in self insured coverage lives or moves to one of the states with its own ACA mandate and fails to receive a 1095-C form, your company could be out of compliance at the state level — even if you followed all federal requirements.
That means employers must:
- Identify where their employees live or file state taxes.
- Maintain accurate address and residency data throughout the year.
- Furnish 1095-C forms according to each state’s rules.
How Trusaic Simplifies Multi-State ACA Compliance
Managing state-level ACA reporting and furnishing manually is complex and time-consuming. Trusaic’s ACA State Reporting solution automates every step:
- Automated State Detection: Identifies employees by state residency to ensure the right furnishing and filing obligations are met.
- Pre-Built State Filing Capabilities: Supports all required state submissions, including California, New Jersey, Rhode Island, and D.C.
- Deadline Monitoring: Tracks filing and furnishing due dates across jurisdictions.
- Penalty Risk Assessment: Detects potential state noncompliance risks before penalties occur.
- Audit Defense: Maintains audit-ready records for both IRS and state agency reviews.
Final Thoughts
While the federal ACA furnishing rule now offers more flexibility, state-level requirements have not changed for most employers.
California, New Jersey, and Rhode Island still require you to furnish 1095-C forms directly to employees — regardless of whether they request them.
Failing to do so could expose your organization to state penalties or enforcement actions.
Trusaic helps ensure compliance across all jurisdictions, automating both federal and state reporting so you can stay focused on your business — not the fine print.