27 March 2020

New Jersey deadline to provide 2019 Forms 1094-C or 1095-C to tax division extended to May 15, 2020 for COVID-19

The New Jersey Treasury Department announced that the deadline for providing a Form 1095 health coverage form to the New Jersey Division of Taxation is extended from March 31, 2020 to May 15, 2020.

As we previously reported, New Jersey employers must provide the New Jersey Division of Taxation with a 2019 Form 1095-B or 1095-C health coverage form for each primary enrollee who was a New Jersey resident and to whom the filer provided minimum essential coverage in 2019. This applies to both part-year and full-year New Jersey residents. (EY Payroll Newsflash Vol. 20, #098, 7-23-2020.)

Employers must ensure that each primary enrollee who was a New Jersey resident or part-year New Jersey resident in 2019 receives at least one Form 1095 that includes health coverage information. Sending a single 1095 to each primary enrollee is sufficient for both state and federal purposes. Employers do not have to send separate Forms 1095 to spouses, dependents, or adult children of primary enrollees.

Background

New Jersey was the first state to indicate it will leverage the federal Forms 1094-C and 1095-C to administer the state's individual mandate. Starting with tax year 2019, the New Jersey Health Insurance Market Preservation Act (Market Preservation Act), which was modeled after the federal Affordable Care Act, requires third-party reporting to verify health coverage information supplied by individual payers of New Jersey's Income Tax.

The Market Preservation Act requires New Jersey residents to maintain minimum essential health insurance coverage throughout 2019 and beyond, unless the individual qualifies for an exemption. Failure to have health coverage or qualify for an exemption will result in a shared responsibility payment when an individual files his or her 2019 New Jersey income tax return.

The federal Tax Cut and Jobs Act set the individual mandate penalty at $0 starting with the 2019 calendar year, effectively repealing the federal penalty.

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Contact Information
For additional information concerning this Alert, please contact:
 
Workforce Tax Services - Employment Tax Advisory Services
   • Kenneth Hausser (kenneth.hausser@ey.com)
   • Debera Salam (debera.salam@ey.com)
   • Kristie Lowery (kristie.lowery@ey.com)

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ATTACHMENT

EY Payroll News Flash

Document ID: 2020-0756