Summary of RY 2025 Employer Obligations
To date, California, the District of Columbia, New Jersey, Rhode Island, and Vermont have passed state individual mandates that are similar to the federal regulations and reporting requirements under the Affordable Care Act. While Massachusetts also passed individual mandate legislation, it predated the federal Affordable Care Act and contains different requirements than the federal regulations and reporting requirements.
Additional states are considering their own state healthcare mandates. These states include Hawaii, Washington, Connecticut, Minnesota, and Maryland. ACA Track will continue to monitor states for new legislation related to individual mandates and employer reporting requirements and update our clients on any relevant changes or additional state requirements.
Vermont Employer Obligations
Vermont does not require any additional Employer Reporting under the State Individual Mandate if the employer reporting requirements under the Affordable Care Act remain in place.
Rhode Island Employer Obligations
Employers (both in-state & out-of-state) who offer MEC coverage to Rhode Island residents at any point during the 2025 calendar year, must submit a return to the state and provide written statements to INSURED employees annually. The 1095 forms required under the Affordable Care Act currently meet the Employee Written Statement requirement for the state.
Rhode Island has clarified their state reporting requirements and confirmed that the state only expects the employer to submit 1095C information as part of the Employer Individual Mandate Return if the employer-offered medical plan is Self-Funded. If the employer-offered medical plan is Fully Funded, then Rhode Island only expects to receive the 1095B information. Rhode Island regulations stipulate that only medical carriers licensed by the state of Rhode Island are required to submit 1095B information returns to the state for Fully Funded medical plans. As such, employers should confirm with all applicable fully funded medical carriers and/or plan sponsors that they will be making this submission to the state of Rhode Island for the 2025 Reporting Year. The employer remains liable for ensuring that the proper reporting has been completed:
- Employers Offering Self-Funded Medical Plans, the employer is responsible for submitting a 1095C to the state of Rhode Island.
- Employers Offering Fully Funded Medical Plans, most insurance carriers will submit forms 1095B to the state and distribute copies to the employees on behalf of the employers. If their insurance carrier fails to file, employers are responsible for fulfilling these obligations to avoid penalties. Employers should act immediately to confirm that their medical carrier will be completing this return on their behalf.
2025 Rhode Island Reporting Year Deadlines:
- Distribute 1095 Statements to Employees – March 2, 2026
- Submit Returns to the State – March 31, 2026
More information can be found here.
District of Columbia (Washington, DC) Employer Obligations
Employers (both in-state & out-of-state) who offer medical coverage to any employee who resided in the District of Columbia at any point during the 2025 calendar year, must submit a return to the state and provide written statements to any employee who was OFFERED medical coverage annually. The 1095 forms required under the Affordable Care Act currently meet the Employee Written Statement requirement for the state.
The District of Columbia requires both the 1095C and the 1095B form to be reported, irrespective of the plan funding method. As such, employers should confirm with all applicable fully funded medical carriers and/or plan sponsors that they will be making this submission to the District of Columbia for the 2025 Reporting Year. The employer remains liable for ensuring that the proper reporting has been completed.
2025 District of Columbia Reporting Year Deadlines:
- Distribute 1095 Statements to Employees – March 2, 2026
- Submit Returns to the State – April 30, 2026
More information can be found here.
California Employer Obligations
Employers (both in-state & out-of-state) who offer MEC coverage to California residents at any point during the 2025 calendar year, must submit a return to the state and provide written statements to INSURED employees annually. The 1095 forms required under the Affordable Care Act currently meet the Employee Written Statement requirement for the state.
California has clarified their state reporting requirements and confirmed that the state only expects the employer to submit 1095C information as part of the Employer Individual Mandate Return if the employer-offered medical plan is Self-Funded. If the employer-offered medical plan is Fully Funded then California only expects to receive the 1095B information, which is generally reported by the medical carrier and/or plan sponsor. While the medical carrier is supposed to provide the 1095B information return to California on the employer’s behalf, employers should confirm with all applicable fully funded medical carriers and/or plan sponsors that they will be making this submission to the state of California for the 2025 Reporting Year. The employer remains liable for ensuring that the proper reporting has been completed.
- Employers Offering Self-Funded Medical Plans, the employer is responsible for submitting a 1095C to the state of California.
- Employers Offering Fully Funded Medical Plans, most insurance carriers will submit forms 1095B to the state and distribute copies to the employees on behalf of the employers. If their insurance carrier fails to file, employers are responsible for fulfilling these obligations to avoid penalties. Employers should act immediately to confirm that their medical carrier will be completing this return on their behalf.
2025 California Reporting Year Deadlines:
- Distribute 1095 Statements to Employees – January 31, 2026
- Submit Returns to the State – March 31, 2026
More information can be found here.
New Jersey Employer Obligations
Applicable Large Employers (both in-state & out-of-state) who offer coverage to New Jersey residents at any point during the 2025 calendar year must submit a return to the state and provide written statements to INSURED employees annually. The 1095 forms required under the Affordable Care Act currently meet the Employee Written Statement requirement for the state.
New Jersey has clarified the state reporting requirements and confirmed that the state only expects the employer to submit 1095C information as part of the Employer Individual Mandate Return if the employer-offered medical plan is Self-Funded. If the employer-offered medical plan is Fully Funded then New Jersey only expects to receive the 1095B information, which is generally reported by the medical carrier and/or plan sponsor. While the medical carrier is supposed to provide the 1095B information return to New Jersey on the employer’s behalf, employers should confirm with all applicable fully funded medical carriers and/or plan sponsors that they will be making this submission to the state of New Jersey for the 2025 Reporting Year. The employer may share liability if its insurer or plan sponsor does not file the required 1095 forms on time.
- Employers Offering Self-Funded Medical Plans, the employer is responsible for submitting a 1095C to the state of New Jersey.
- Employers Offering Fully Funded Medical Plans, most insurance carriers will submit forms 1095B to the state and distribute copies to the employees on behalf of the employers. If their insurance carrier fails to file, employers are responsible for fulfilling these obligations to avoid penalties. Employers should act immediately to confirm that their medical carrier will be completing this return on their behalf.
2025 New Jersey Reporting Year Deadlines:
- Distribute 1095 Statements to Employees – March 2, 2026
- Submit Returns to the State – March 31, 2026
More information can be found here.
Massachusetts Employer Obligations
Unlike other States, Massachusetts requires employers to file the State-specific Form MA 1099-HC for health coverage reporting. Massachusetts has an “individual health insurance mandate” which requires most adults to carry health insurance if it is affordable to them and that meets certain coverage standards (referred to as “Minimum Creditable Coverage” or MCC). The Massachusetts Health Connector sets the coverage and affordability standards, and the Massachusetts Department of Revenue (DOR) administers the requirement via the state tax filing process. Please note that the standards are specific to the Massachusetts health reform law (not the Affordable Care Act, the federal health reform law).
Employers who provide MCC to MA residents must submit the health coverage documents to the state, indicating that they meet Minimum Creditable Coverage (MCC).
They must also distribute copies to employees (residents of Massachusetts) so that they can complete their tax returns.
- Employers who are self-insured must ensure that the MA 1099-HC forms are filed with the state and distributed to employees either by themselves or their Third-Party Administrator (TPA).
- Employers Offering fully insured plans, most insurance carriers will submit forms MA 1099-HC to report minimum creditable coverage to the state and distribute copies to the employees on behalf of the employers. If their insurance carrier fails to file, employers are responsible for fulfilling these obligations to avoid penalties.
Massachusetts Reporting Year Deadlines:
- Distribute 1099 HC Statements to Employees – January 31
- Submit Returns to the State – January 31
More information can be found here.