Deadlines are approaching for several important reporting obligations with respect to the federal Affordable Care Act (ACA) and states with ACA-style individual mandates for health insurance coverage.

ACA Reporting (Federal)

• Deadline for employers with self-insured plans to electronically file Forms 1094- and 1095-C: March 31.
• Electronic filing is mandatory for applicable large employers (ALEs) filing 250 or more 1095-C forms.

State Individual Mandate Reporting – California

• Deadline to file Forms 1094- and 1095-C with the California Franchise Tax Board: March 31, 2022.

State Individual Mandate Reporting – Massachusetts

• Unlike other state individual mandates that rely on federal forms to implement their reporting requirements, Massachusetts mandates that employers prepare and file the Massachusetts-specific 1099-HC form.
• Deadline to electronically submit 1099-HC forms to the Commonwealth via MassTaxConnect: March 31, 2022.

State Individual Mandate Reporting – New Jersey

• Deadline to electronically submit Forms 1094- and 1095-C to the state: March 31, 2022.

State Individual Mandate Reporting – Rhode Island

• Deadline to electronically file Forms 1094- and 1095-C with the State of Rhode Island: March 31, 2022.

Individual Mandate Reporting – District of Columbia

• Deadline to electronically submit Forms 1094- and 1095-C to the D. C. Office of Tax and Revenue: 30 days after IRS submission deadline, i.e., April 30, 2022.