Updated NJ Health Insurance Mandate Information

Beginning Jan. 1, 2019, NJ requires its residents to maintain health insurance throughout 2019 and beyond (unless an exemption applies). NJ recently updated its website to detail the requirement of employers to verify the information provided by individual taxpayers.

As background, Gov. Murphy signed the Health Insurance Market Preservation Act on May 30, 2018, requiring every NJ resident to have health coverage or pay a penalty (shared responsibility payment). This state mandate mirrors the former federal individual mandate imposed by the ACA and intends to require NJ residents to purchase health care so that the NJ health insurance market will remain stable and provide more affordable rates of coverage. We initially discussed the individual mandate shortly after it became law in Compliance Corner.

Beginning in 2020, the NJ legislature will require employers with at least 50 employees to provide Form 1094-C, “Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns,” and Form 1095-C, “Employer-Provided Health Insurance Offer and Coverage,” that they currently provide to taxpayers and the IRS to the NJ Div. of Taxation. Copies of the forms must be submitted on or before Feb. 15 following the close of each calendar year. This NJ reporting requirement mirrors the current ACA reporting requirements, but if the federal government discontinues the use of Forms 1094-C or Forms 1095-B and 1095-C at some point in the future, then NJ will deploy similar forms for the ongoing filing requirement.

Similar to the federal requirement, NJ does not require dependent information, including adult children who are covered by their parents’ plans. However, it is recommended that employers advise employees to provide a copy of any Form 1095-B or 1095-C containing coverage information to their children residing in NJ.

NJ employers should review the NJ website for the reporting requirements and make note of the Feb. 15 deadline to provide the Forms 1094-C and 1095-C starting in 2020. Please also note that this reporting requirement also applies to out-of-state employers that withhold and remit NJ gross income tax for NJ residents.

For more information, employers can visit the NJ Health Insurance Mandate website.

The NJ Health Insurance Market Preservation Act »