Additional 1095-C Filing Guidance for Employers with Employees Who Reside in NJ

In connection with NJ’s individual mandate (which took effect in 2019), employers with employees who reside in NJ must file (or coordinate filing with their carrier) IRS Form 1095-C (or 1095-B, in some instances) with NJ. We have covered the filing requirements previously in the January 22, 2020, edition of Compliance Corner. NJ previously announced that employers must file electronically using the NJ Division of Revenue and Enterprise Services’ MFT SecureTransport service. This has caused angst among employers, since many employers may have only a handful of NJ-residing employees for whom they must report, and many employers may not be able to meet the appropriate formatting and technical requirements to file through the NJ SecureTransport service.

The additional guidance clarifies that there is a new manual process for employers that had fewer than 50 employees living in NJ during 2019. Under the manual process, the employer essentially keys in the Form 1095-C information for each NJ resident. The manual process, which uses the “Fillable Form NJ-1095” is outlined under the “Transmitting 1095 Returns” section at the below link. In addition to considering the new manual process, employers should reach out to their payroll provider or their IRS 1095-C filing vendor to see if the provider/vendor can assist with the NJ filings. While most provider/vendor contracts likely don’t address new state filings such as the NJ filing, it’s possible the provider/vendor would agree to add those services to the contract.

NFP Benefits Compliance will continue to monitor the NJ filing requirement issue, and report future developments here in Compliance Corner.

Guidance »