Massachusetts State Reporting

MA Employer Obligations

• Employer Health Insurance Responsibility Disclosure (HIRD)undefined
• Who Files: Employers with six or more employees in Massachusetts must complete the HIRD form, regardless of whether they offer insurance.
• Filing Process: The form is submitted electronically through the Massachusetts Department of Revenue's MassTaxConnect portal.
• Deadline: The HIRD form becomes available on November 15 and must be completed by December 15 each year
• Information Collected: The form collects employer-level information about employer-sponsored insurance (ESI) offerings, including details like employee monthly contributions, in-network deductibles, out-of-pocket maximums, eligibility requirements, plan year, and total monthly cost of the plan

MA Employee Obligations

• Form MA 1099-HC:
• Requirement: Massachusetts residents must have health insurance that meets Minimum Creditable Coverage (MCC). Insurers or employers who provide health insurance are required to file Form MA 1099-HC with the Massachusetts Department of Revenue (DOR) and furnish a copy to individuals.
• Contents: This form indicates whether the individual was covered for each month of the year. The coverage must meet MCC standards, which outline specific benefits like prescription drug coverage, mental health services, etc.
• Who Needs to File: Employers who provide health insurance through a Massachusetts-based insurer do not have to worry about generating this form; it’s the responsibility of the insurance carrier. However, employers who are self-insured must ensure that the form is issued either by themselves or their Third-Party Administrator (TPA).

Vermont:

Vermont does not require any additional employer reporting under its state individual mandate, provided that the employer continues to meet the reporting requirements set forth by the Affordable Care Act (ACA). As long as the federal ACA regulations remain in place, Vermont imposes no further employer obligations.

Rhode Island:

Employers (both in-state and out-of-state) who provide Minimum Essential Coverage (MEC) to Rhode Island residents at any point during the calendar year must submit a return to the state and issue written statements to employees annually. The 1095 forms required under the ACA satisfy the Employee Written Statement requirement for Rhode Island.

For self-funded medical plans, employers are required to submit 1095-C information as part of Rhode Island’s Individual Mandate Return. For fully funded medical plans, employers may submit the 1095-C information only if the insurance carrier is not licensed or otherwise authorized by the Rhode Island Office of the Health Insurance Commissioner to offer coverage. If the plan is fully funded and the carrier is licensed and authorized by the Rhode Island Office of the Health Insurance Commissioner, the carrier must submit the 1095-B information to the state on the employer's behalf. D

District of Columbia (Washington, D.C.):

Applicable Large Employers (ALEs), both in-state and out-of-state, who provide health coverage to residents of the District of Columbia or employees with a DC mailing address (regardless of payroll tax withholdings) must submit a return to the District and provide written statements to employees annually. The 1095 forms required under the ACA meet the Employee Written Statement requirement. Both 1095-C and 1095-B forms must be submitted to the District, regardless of the funding method of the medical plan.

California:

Employers (both in-state and out-of-state) providing MEC to California residents must submit a return to the state and issue written statements to employees annually. The 1095 forms required under the ACA fulfill the Employee Written Statement requirement.

For self-funded medical plans, California requires employers to submit 1095-C information as part of the Employer Individual Mandate Return. For fully funded plans, California expects 1095-B information, which is typically submitted by the medical carrier or plan sponsor. Employers should confirm with their fully funded medical carriers or plan sponsors that they will submit the 1095-B information on the employer’s behalf. Employers remain responsible for ensuring accurate reporting.

- Self-Funded Medical Plans: Employers must submit a return containing 1095-C information for the current Reporting Year.

- Fully Funded Medical Plans: Employers should ensure that their medical carrier will submit the 1095-B information return to California. Employers should act promptly to confirm this reporting.

New Jersey:

Applicable Large Employers (both in-state and out-of-state) who provide health coverage to New Jersey residents must submit a return to the state and issue written statements to employees annually. The 1095 forms required under the ACA fulfill the Employee Written Statement requirement.

For self-funded medical plans, employers must submit 1095-C information as part of New Jersey’s Employer Individual Mandate Return. For fully funded plans, New Jersey expects 1095-B information, which is usually submitted by the medical carrier or plan sponsor. Employers should verify with their fully funded medical carriers or plan sponsors that they will submit the 1095-B information on the employer’s behalf. Employers may be liable if the carrier fails to submit the required forms on time.

- Self-Funded Medical Plans: Employers must submit a return containing 1095-C information for the current Reporting Year.

- Fully Funded Medical Plans: Employers must ensure their medical carrier will submit the 1095-B information return.