Vermont Employer Obligations Overview: Vermont does not require any additional Employer Reporting under the State Individual Mandate as long as the employer reporting requirements under the Affordable Care Act remain in place.

Rhode Island Employer Obligations Overview: Employers (both in-state & out-of-state) who offer MEC coverage to Rhode Island residents at any point during the current calendar year must submit a return to the state and provide written statements to employees annually. The 1095 forms required under the Affordable Care Act currently meet the Employee Written Statement requirement for the state. The state of Rhode Island requires employers to submit the 1095C Information as part of the Individual Mandate Return for any medical plan that is Self Funded, and may submit the same if the medical plan is Fully Funded and the carrier is not licensed or otherwise authorized by the Rhode Island Office of the Health Insurance Commissioner to offer health coverage. If medical plan is Fully Funded and the carrier is licensed and authorized by the Rhode Island Office of the Health Insurance Commissioner to offer health coverage, then the carrier is required to submit the 1095B Information to the state on behalf of the employer. 2022 Rhode Island Reporting Year Deadlines will be forthcoming.

District of Columbia (Washington, DC) Employer Obligations Overview: Applicable Large Employers (both in-state & out-of-state) who offer coverage to District of Columbia residents and/or employees with a DC mailing address, regardless if payroll taxes are withheld for the jurisdiction, at any point during the current calendar year must submit a return to the District and provide written statements to employees annually. The 1095 forms required under the Affordable Care Act currently meet the Employee Written Statement requirement for the District. The District of Columbia requires both the 1095C and the 1095B form to be reported, irrespective of the plan funding method. 2022 District of Columbia Reporting Year Deadlines will be forthcoming.

California Employer Obligations Overview: Employers (both in-state & out-of-state) who offer MEC coverage to California residents at any point during the current calendar year must submit a return to the state and provide written statements to employees annually. The 1095 forms required under the Affordable Care Act currently meet the Employee Written Statement requirement for the state. California has clarified their state reporting requirements and confirmed that the state only expects the employer to submit 1095C information as part of the Employer Individual Mandate Return if the employer-offered medical plan is Self Funded. If the employer-offered medical plan is Fully Funded then California only expects to receive the 1095B information, which is generally reported by the medical carrier and/or plan sponsor. While the medical carrier is supposed to provide the 1095B information return to California on the employer’s behalf, employers should confirm with all applicable fully funded medical carriers and/or plan sponsors that they will be making this submission to the state of California for the current Reporting Year. The employer remains liable for ensuring that the proper reporting has been completed.

• Employers Offering Self Funded Medical Plans – a return containing the 1095C information must be submitted to the state of California for the current Reporting Year.

• Employers Offering Fully Funded Medical Plans – a return containing only the 1095B information must be submitted to the state of California for the current Reporting Year. Employers should act immediately to confirm that their medical carrier will be completing this return on their behalf. 2022 California Reporting Year Deadlines will be forthcoming.

New Jersey Employer Obligations Overview: Applicable Large Employers (both in-state & out-of-state) who offer coverage to New Jersey residents at any point during the current calendar year must submit a return to the state and provide written statements to employees annually. The 1095 forms required under the Affordable Care Act currently meet the Employee Written Statement requirement for the state. New Jersey has clarified the state reporting requirements and confirmed that the state only expects the employer to submit 1095C information as part of the Employer Individual Mandate Return if the employer-offered medical plan is Self Funded. If the employer-offered medical plan is Fully Funded then New Jersey only expects to receive the 1095B information, which is generally reported by the medical carrier and/or plan sponsor.

While the medical carrier is supposed to provide the 1095B information return to New Jersey on the employer’s behalf, employers should confirm with all applicable fully funded medical carriers and/or plan sponsors that they will be making this submission to the state of New Jersey for the current Reporting Year. The employer may share liability if its insurer or plan sponsor does not file the required 1095 forms on time.

• Employers Offering Self Funded Medical Plans – a return containing the 1095C information must be submitted to the state of New Jersey for the current Reporting Year.

• Employers Offering Fully Funded Medical Plans – a return containing only the 1095B information must be submitted to the state of New Jersey for the current Reporting Year. Employers should act immediately to confirm that their medical carrier will be completing this return on their behalf. 2022 New Jersey Reporting Year Deadlines will be forthcoming.

State Reporting