On March 19, 2020, the New Jersey Department of Treasury announced that it extended the deadline for applicable coverage providers to file Forms 1095 with the New Jersey Division of Taxation from March 31, 2020, to May 15, 2020. This filing requirement applies to in-state and out-of-state coverage providers that provided minimum essential health coverage to part-year or full-year residents of New Jersey in 2019, including insurers, employers, governmental agencies, and multiemployer plans.

In addition to providing Forms 1095 to the New Jersey Division of Taxation, an applicable coverage provider must have provided primary enrollees with Forms 1095-B or 1095-C by March 2, 2020. A coverage provider may send one Form 1095 to a primary enrollee to satisfy state and federal reporting requirements. This March 2, 2020, deadline has not been extended.

A few other states impose health coverage reporting requirements but they have not yet announced extended deadlines. The District of Columbia’s Office of Tax and Revenue currently requires that an applicable entity upload the same Forms 1094-B, 1095-B, 1094-C and 1095-C that they file with the IRS to the D.C. Office of Tax and Revenue by June 30, 2020. California and Rhode Island impose similar reporting requirements, but applicable entities are not required to report until 2021.

We will continue monitoring state mandated health coverage reporting deadlines in light of the COVID-19 situation.