As we approached the March 2, 2020 Form 1095-C issuance
deadline, Baker Tilly Vantagen was proud to be able to report that all forms
for contracted clients were released in compliance with the 2019 tax year’s
extended issuance deadline. With this
important first step in the annual ACA reporting process now complete, our
attention has turned to situating this data with the IRS and, for the first
time, state-level agencies.
The federal deadline for transmitting Form 1094-C and 1095-C data to the IRS via its Affordable Care Act Information Returns (AIR) system is March 31, 2020. Baker Tilly Vantagen is actively transmitting XML files coded to IRS specifications and sharing results with clients. We also are positioning to support impacted employers with the transfer of related information to states as downstream requirements associated with resurrected the individual coverage mandates.
New Jersey (due March 31, 2020)
Starting with Tax Year 2019, the New Jersey Health Insurance
Market Preservation Act (Market Preservation Act) requires third-party
reporting to verify health coverage information supplied by individual payers
of New Jersey’s Income Tax. By March 31,
2020, employers must provide the New Jersey Division of Taxation with a 1095
health coverage form for each primary enrollee who was a New Jersey resident
and to whom the filer provided minimum essential coverage in 2019. This requirement
applies to both part-year and full-year New Jersey residents. For 1095 filing
purposes, a part-year resident is a primary enrollee who lived in New Jersey
for at least 15 days in any month. New
Jersey will not require 1094 forms for 2019, though it will accept them when
New Jersey allows employers with fully-insured plans to
satisfy state reporting through the information returns filed with the state by
their insurance providers. If your
organization falls under this category, you will want to inquire with your
insurance provider to assess their readiness to meet the applicable deadline.
Employers offering self-insured
plans can file 1095 forms with the state in two ways:
- Registered filers can use the Division of Revenue and Enterprise Services’ (DORES) MFT SecureTransport service. MFT is the required system for filers of 100 or more forms. Taxpayers who have MFT SecureTransport service user credentials use them to submit the required health insurance coverage returns.
- As an alternative to MFT SecureTansport, coverage providers with under 100 forms can use a fillable form NJ-1095 to file one form at a time. The NJ-1095 form is valid for federal filers of either 1095-B or 1095-C forms.
There is no paper filing option available.
Baker Tilly Vantagen has reconfigured its systems to allow
for IRS AIR files to be generated for a population that is limited to a
particular state of residence. We also
have secured access to the systems prescribed by the state for file sharing
purposes. Taking these measures
positions us to complete this filing deliverable on behalf of our employer
clients and do so in a way that ensures the minimum amount of data necessary to
support compliance with a state-level mandate is transferred to a designated
District of Columbia (due June 20, 2020 for 2019 reporting only)
In DC, the reporting requirement encompasses any employee
for whom the employer withholds DC taxes. Reporting also applies to any
employee who has a DC mailing address, even if the employer doesn’t withhold
and report DC taxes. Employers that furnish covered employees with MEC notices
for federal purposes do not have to provide duplicate notices for DC.
All information returns must be uploaded through
MyTax.DC.gov, using the DC Office of Tax and Revenue (0TR) prescribed layouts and file formats. Entities
may contract with third-party providers to complete the filing. Any filer that
doesn’t currently have a MyTax.DC.gov account will have to sign up to obtain
It remains unclear if DC will allow employers with
fully-insured plans to satisfy state reporting through the information returns
filed with the state by their insurance providers.
California, Rhode Island, and Vermont enacted individual coverage mandates effective January 1, 2020. California will allow employers with fully insured plans to satisfy state reporting through the information returns filed with the state by their insurance providers. Vermont will not require employers to satisfy coverage reporting requirements unless and until federal reporting is repealed.
Baker Tilly Vantagen will charge a per transmittal fee based
on a variety of factors including population size, number of FEINs and the
uniqueness of each state’s reporting requirement. When applicable, your Account Manager will
communicate your company’s fee proposition this week and be available to field
any questions you may have regarding state-level reporting requirements.
The information provided here is of a general nature and is not intended to address the specific circumstances of any individual or entity. In specific circumstances, the services of a professional should be sought. Tax information, if any, contained in this communication was not intended or written to be used by any person for the purpose of avoiding penalties, nor should such information be construed as an opinion upon which any person may rely. The intended recipients of this communication and any attachments are not subject to any limitation on the disclosure of the tax treatment or tax structure of any transaction or matter that is the subject of this communication and any attachments.