Insights

Deadlines Extended for Individual Mandate Reporting


As part of Rhode Island’s individual mandate, employers providing minimum essential coverage to Rhode Island residents must file a return with the Division of Taxation and a return to each individual.

Generally, reporting to Rhode Island residents and the division is due by January 31. For tax year 2020 only, the deadline has been extended to March 2, 2021 (to distribute returns to employees) and to March 31, 2021 (to file with the division).

As background, as of January 1, 2020, Rhode Island residents are required to have qualifying healthcare coverage, or pay a penalty (a “shared responsibility payment”), unless a hardship, religious, or other exemption applies. As part of this requirement, certain employers have reporting obligations to the division and to individuals. The law provides that Forms 1095-B and 1095-C issued by the employer for federal reporting purposes is sufficient to meet the Rhode Island reporting requirement but also provides an option to report via a flat file containing the same information.

Generally, employers will need to distribute Form 1095-C to employees and the IRS – which are current requirements under the ACA’s employer mandate – and then to the division by January 31 of the year following the calendar year for which the return was required to be made. However, the deadline to distribute Form 1095-C to employees has been extended to March 2, 2021, and the deadline to file with the division to March 31, 2021. These extensions only apply to tax year 2020 reporting. Plan sponsors of fully insured plans should note that if the insurer completes the reporting requirements described above, then no further reporting is required.

Employers with employees located in Rhode Island should be aware of these developments.

Department of Revenue Health Insurance Mandate Reporting Requirements FAQ »