Includes: California, DC, New Jersey,

& Rhode Island

California

Insurance providers, including self-funded/level-funded plan sponsors, are required to report health coverage information for residents to State of California Franchise Tax Board (FTB). Employers are similarly required to report insurance information if their insurance providers do not report to FTB.

California FTB requires information to be furnished to employees by January 31 and reporting to the FTB by March 31.

UPDATE: California Franchise Tax Board (FTB) filing instructions were recently updated to say FTB will not penalize insurers and self-funded employers for missing the March 31, 2021, deadline to file – if the filing is completed within the following two months (by May 31, 2021). NOTE:  The state can impose a $50 per form penalty for filings received after the deadline.

We were also informed by a representative at FTB that there will be no penalty for missing the Jan. 31, 2021 deadline for furnishing proof of insured coverage (and self-insured employers to furnish proof of self-insured coverage) for 2020 to California residents.  The representative encouraged employers/plan sponsors to meet the March 2, 2021 postmark deadline, which IS being enforced by the IRS.

District of Columbia

All employers that employ residents of the District of Columbia are required to report health coverage information to the Office of Tax and Revenue (OTR).  

Compliance with IRS guidelines regarding distribution of forms will be considered fulfilling the District’s requirements to furnish information to employees/covered individuals. 

The District requires information to be furnished to OTR 30 days after the IRS deadline for electronic submissions.  For Tax Year 2020, the OTR deadline is April 30, 2021.

New Jersey

Insurance providers, including self-funded/level-funded plan sponsors, are required to report health coverage information for residents to New Jersey.  Employers are similarly required to report insurance information if their insurance providers do not provide the required information to New Jersey.

New Jersey does NOT follow all IRS practices on distribution of the 1095B.  New Jersey requires that a 1095B form be sent to each primary enrollee – postmarked by March 2, 2021 for Tax Year 2020.  New Jersey requires information to be submitted electronically by March 31, 2021.

Rhode Island

Insurance providers, including self-funded/level-funded plan sponsors, are required to report health coverage information for residents to Rhode Island Division of Taxation.  Employers are similarly required to report insurance information if their insurance providers do not report to the Division. 

Rhode Island requires information to be furnished to employees and the Division of Taxation by January 31 each year. 

For Tax Year 2020 ONLY, the Division of Taxation has extended the furnishing deadline to March 2, 2021 and to the Division to March 31, 2021.

---

If you provided health insurance coverage to individuals while they were a resident of any of these states, you may have a reporting responsibility.  Please check your records carefully. 

A Reporting Only State Filing subscription to the ACA Management Tool^® allows you to e-file securely with these States.  Contact ACA GPS today.