Updated Employer Guidance For Individual Mandate

NJ recently updated their guidance on the employer filing requirements related to the state’s individual health insurance mandate. As discussed in the January 23, 2019, edition of Compliance Corner, NJ residents are required to maintain health insurance as of January 1, 2019. The law requires that employers provide third-party reporting to verify the coverage information initially provided by individual taxpayers.

This third-party verification requires employers to provide NJ taxpayers and the state with the same 1094 and 1095 health-care coverage information sent to the IRS. The employer filing requirements vary depending upon whether the employer is fully-insured, self-insured or a participating employer in a multi-employer plan. The size of the company also impacts the reporting requirements. Generally though, employers that filed Form 1094-C/Form 1095-C federally in 2018, may use those forms for purposes of NJ reporting. Similarly, filers of Form 1094-B/Form 1095-B should use those forms. Out of state employers that withhold and remit NJ gross income tax for residents have the same filing requirements.

Employers must verify health coverage through the same electronic system used for filing W-2 forms. The guidance clarifies that should the federal government discontinue or substantially alter Forms 1094-B, 1094-C, 1095-B, or 1095-C, NJ will issue similar forms to continue the third-party verification requirements.

The deadline for employers to file 2019 coverage verification information is February 15, 2020.

NJ Health Insurance Mandate Website »