November 12, 2020
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.
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.