ACA Filings for Employers with NJ Resident Employees Due 3/31
March 16th, 2020
As you may be aware, as of January 1, 2019 the State of New Jersey enacted a mandate requiring New Jersey residents to maintain Minimum Essential Health Coverage, mirroring the requirements of the federal Affordable Care Act. As a result, New Jersey’s Health Insurance Market Preservation Act (HIMPA) has added new cumbersome reporting requirements for employers that have New Jersey residents. These applicable employers are now required to provide the state of New Jersey with the federal 1095 health coverage form for each primary enrollee in 2019, by March 31, 2020.
While employers who sponsor a fully-insured health plan are ultimately responsible, we’ve been advised that the medical insurance carriers are fulfilling this requirement on your behalf. For self-insured (which includes level-funded plans), employers should contact their payroll company or ACA reporting vendor to determine if they are providing this as a service. If not employers are responsible for conducting this filing directly with the state of New Jersey. Employers with more than 100 forms are required to use the Axway bulk filing system, while smaller groups that are able to meet the electronic filing requirements also have this as an option. This process requires the uploading of an .xml file (this is the same file schema required by the IRS for your federal 1095 filing). The requirements for the .xml schemas can be found at: https://www.irs.gov/e-file-providers/air/affordable-care-act- information-returns-schemas.
Please note that while this communication applies to employers with New Jersey residents, other states have also issued similar reporting requirements that may apply to you. At Innovative we are prepared to help and understand these new compliance requirements can be complicated.
Please contact us with any questions.
