While the federal ACA filing deadline of March 31 has passed, employers should be aware of upcoming state-specific reporting requirements. Notably, Washington D.C. and California have deadlines on April 30 and May 31, respectively.
It’s essential for organizations operating in these jurisdictions to comply with these mandates to avoid potential penalties.
Understanding State ACA Reporting Obligations
Several states have implemented individual mandates requiring employers to report health coverage information to ensure residents maintain minimum essential coverage. Failure to comply can result in financial penalties and increased scrutiny. Massachusetts, New Jersey, and Rhode Island’s filing deadlines all coincide with the federal March 31 deadline.
Washington D.C. has a separate deadline of April 30 and California has an extended deadline that allows employers to file by May 31.
Washington D.C.’s requirements include:
- Any organization that provides MEC to at least one D.C. resident (and their dependents) must report this information to the state government
- Specifically, organizations must file all forms with the D.C. Office of Tax and Revenue (OTR), once per year
- The law also requires employers to make this coverage information available (via copies of Form 1095-B/C) to insured employees
- Only Applicable Large Employers (ALEs) are required to file reports. The law applies to any ALEs who employ D.C. residents, regardless of whether they withhold D.C. payroll taxes
- Fully insured employers are subject to D.C. ACA reporting requirements
- Employers must electronically file Forms 1094 and 1095-B / 1095-C with the D.C. OTR. Paper filing is not accepted.
Washington D.C. has not indicated whether there are penalties for non-compliance with this deadline.
California’s requirements include:
- Organizations who employ California residents must file, regardless of whether the organization is located in or out of state.
- Employers must report employee insurance information with the California Franchise Tax Board (FTB) once per year
- Information should be submitted to the state using federal Forms 1094-C, 1095-C, and 1095-B. Organizations must also distribute copies to employees.
- You should not submit forms for employees who were offered coverage but did not enroll
- If your organization offers full insurance plans, the insurance company may report information to the state about each individual enrolled in coverage. If the insurer fails to do this, employers can be held responsible and fined.
- You can file electronically or by mail. The FTB encourages electronic filing. If you are filing more than 250 forms of a certain type, you must file electronically. For example, if you have 500 Forms 1095-C and 75 Forms 1095-B, you do not need to file Forms 1095-B electronically.
Employers that fail to meet the California ACA reporting requirements may be fined $50 per individual not reported on.
Ensuring Compliance with Trusaic’s ACA State Filing Solution
Navigating the complexities of state-specific ACA reporting can be challenging. If you are an organization that handles ACA compliance in-house, it’s important to determine whether you have state filing obligations. If you have yet to file for Washington D.C. or California, Trusaic offers a comprehensive ACA State Filing solution designed to streamline the compliance process.
Our services include:
- Accurate Filing: Prepare and submit state-specific reports to ensure timely and precise compliance.
- Penalty Risk Assessment: Identify and address compliance gaps proactively to minimize potential liabilities.
- Employee Address Tracking: Monitor employee relocations to prevent reporting discrepancies.
- Expert Support: Collaborate with our ACA compliance specialists for seamless filing and reporting.
Trusaic’s ACA compliance service enables you to offload 1095-C furnishing and filing responsibilities. We deliver everything you need to track, prepare, furnish and file 1095-C forms. We provide monthly monitoring so you receive alerts for when offers of coverage are required and our penalty risk assessment tool identifies coverage gaps and enables you to address liabilities quickly.
As state ACA reporting deadlines approach, it’s imperative for employers to remain vigilant and ensure compliance with all applicable requirements. Leveraging Trusaic’s ACA State Filing solution can simplify the process, reduce the risk of penalties, and provide peace of mind. Don’t let state deadlines catch you off guard — take proactive steps to fulfill your ACA reporting obligations today.