Employers Must File State Health Coverage Reports in Six Jurisdictions
Employers with employees residing in California, the District of Columbia, Massachusetts, New Jersey, Rhode Island or Vermont must submit health coverage reports to each state’s tax authority in addition to filing federal Forms 1094-C and 1095-C with the IRS. The federal filing does not satisfy any of these state obligations, and vendors or payroll providers handling ACA reporting do not automatically cover the state filings.
Massachusetts uses a unique reporting system, requiring Form MA 1099-HC for individual coverage and a separate Health Insurance Responsibility Disclosure (HIRD) form, both filed through MassTaxConnect by December 15. California and New Jersey impose a $50 penalty per covered individual for late or missing filings, and the filing trigger is the employee’s residence, not the employer’s location.
Vermont has an individual mandate but currently imposes no employer filing requirement. Deadlines for 2026 coverage year data range from late January to April 2027, with most states requiring submissions between March and April. Employers should map employee residence locations, determine applicable mandates, confirm filing responsibility, and obtain written confirmation before the filing season begins.
Why it matters
Missing a state health coverage filing can expose employers to per-person penalties and compliance risk across multiple jurisdictions.
FAQ
Which jurisdictions require employer health coverage reporting?
California, the District of Columbia, Massachusetts, New Jersey, Rhode Island and Vermont.
What penalty does California impose for late or missing filings?
California assesses a $50 penalty per covered individual not reported on time.
When must Massachusetts employers file the HIRD form?
The HIRD form must be filed through MassTaxConnect by December 15.
Does filing federal ACA forms satisfy state reporting obligations?
No, federal Forms 1094-C and 1095-C do not satisfy any of the state filing requirements.
Source: Insurance Business America. See the original source for full details.
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