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November 12, 2020
2020-2678

Rhode Island issues guidance on ACA reporting deadlines

The Rhode Island Department of Revenue and Division of Taxation has issued FAQs on employer reporting under the state individual mandate. For the 2020 tax year, employers must furnish Form 1095-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, to individuals by March 2, 2021, and file the form with the state by March 31, 2021.

Background

After Congress eliminated the financial penalty imposed by the Affordable Care Act's (ACA) shared responsibility provision (individual mandate), several states adopted their own requirements. Washington, D.C., New Jersey, Vermont, California and Rhode Island have passed some form of an individual mandate. Each of these jurisdictions leverage the federal Form 1095-C for purposes of administering its individual mandate requirement.

The Rhode Island individual mandate goes into effect on January 1, 2021. Although Rhode Island had established an effective date for the mandate, it had not established a deadline for fulfilling the reporting requirements until it issued FAQs on November 5, 2020. According to the FAQs, employers must file Form 1095-C with the Division of Taxation and furnish it to individuals by January 31. However, for the 2020 tax year, furnishing Form 1095-C to individuals is extended until March 2, 2021, and filing with the state is extended until March 31, 2021. Employers may file the forms electronically using the IRS XML schemas or a flat .csv file containing the same information as the 1095-B. Employer penalties have not been published.

The following chart shows the deadlines for all states with an individual mandate.

State

Requirements

TY 2020 deadline

Washington D.C.

Employee/non-employee delivery:

Form 1095-C

State filing: Forms 1094-C and 1095-C to the DC Office of Tax and Revenue

February 1, 2021 (likely to include any federal extension)

Deadline is 30 days after IRS deadline, including any extensions granted

New Jersey

Employee/non-employee delivery:

Form 1095-C

State filing: Form 1095-C to the NJ Department of the Treasury

February 1, 2021 (likely to include any federal extension)

March 31, 2021

California

Employee/non-employee delivery:

Form 1095-C

State filing: Forms 1094-C and 1095-C to the CA Franchise Tax Board

February 1, 2021 (not likely to include any federal extension)

March 31, 2021 (automatic extension to May 31, 2021)

Rhode Island

Employee/non-employee delivery:

Form 1095-C

State filing: Form 1095-C to the RI Division of Taxation

March 2, 2021

March 31, 2021

Vermont

No filing requirement

 

Massachusetts

State filing: Form 1099-HC to the MA Department of Revenue

January 31, 2021

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Contact Information
For additional information concerning this Alert, please contact:
 
Workforce Tax Services/Affordable Care Act
   • Julie Gallina (julie.gallina@ey.com)
   • Alan M. Ellenby (alan.ellenby@ey.com)