Employers Must File State Health Coverage Reports in Six Jurisdictions
Employers with workers residing in six U.S. jurisdictions—California, the District of Columbia, Massachusetts, New Jersey, Rhode Island, and Vermont—must file health-coverage reports with each state’s tax authority in addition to the federal ACA Forms 1094-C and 1095-C. The federal filing alone does not satisfy any of these state obligations, and the vendors, payroll providers, or carriers that handle the federal filing often do not automatically submit the required state reports.
Each of the six jurisdictions enacted its own individual health-coverage mandate after the federal individual-mandate penalty was reduced to zero in 2019. Five of the six require active employer reporting; Vermont’s mandate currently imposes no filing requirement. Massachusetts stands out because it does not accept the standard 1095-C form. Instead, employers must submit Form MA 1099-HC for individual coverage and a separate Health Insurance Responsibility Disclosure (HIRD) form through MassTaxConnect, with the HIRD deadline of December 15, well before most other state windows.
Penalties for missed or late filings vary. California assesses a $50 penalty per covered individual not reported on time, and New Jersey imposes a $50 penalty per form for late or missing submissions. The trigger for liability is the employee’s residence, not the employer’s headquarters, meaning a company based in a state without a mandate can still incur state filing duties when an employee lives in any of the six jurisdictions. State filing deadlines for 2026 coverage data run from late January through April 2027, with most due between March and April, while Massachusetts requires its HIRD filing by mid-December.
Employers should map employee work and residence locations, determine which state mandates apply, and confirm which party—vendor, carrier, or the employer itself—is responsible for each filing. Written confirmation of responsibility is essential before the filing season begins; if no party accepts the duty, the employer bears it by default.
Why it matters
Missing state health-coverage filings can result in per-person penalties, adding unexpected costs for insurers and their corporate clients.
FAQ
Which states require employers to file health-coverage reports beyond the federal ACA filing?
California, the District of Columbia, Massachusetts, New Jersey, Rhode Island, and Vermont.
What penalties do California and New Jersey impose for late or missing state filings?
Both states assess a $50 penalty per covered individual (California) or per form (New Jersey) for late or missing filings.
What unique filing requirement does Massachusetts have for employer health-coverage reporting?
Massachusetts requires Form MA 1099-HC for individual coverage and a separate HIRD form filed through MassTaxConnect by December 15.
When are the state filing deadlines for the 2026 coverage year?
Deadlines run from late January through April 2027, with most falling between March and April.
Source: Insurance Business America. See the original source for full details.
Scan with your phone
Scan with your phone