What
Separate state-level reporting of minimum essential coverage for employees who reside in California, DC, Massachusetts, New Jersey, or Rhode Island, required in addition to federal ACA 1094/1095 filings. Each state has its own form requirements, portal, and deadline.
Who
Any employer or coverage provider with employees or covered individuals residing in a mandate state, including out-of-state employers. For fully insured plans, the insurer typically files; for self-funded plans, the employer files. Confirm the arrangement with your carrier in writing each year.
When
Deadlines vary by state, ranging from January 31 (MA) to April 30 (DC) of the year following the coverage year. See the Deadlines section for current dates by state.
Risk
States cross-check employer filings against individual tax returns and may issue notices to employees. Missing or incorrect filings can trigger per-return or per-day penalties and state audits. The most common mistake: assuming the carrier handles all state filings when you have a self-funded plan, or when the carrier simply fails to file on time. For PCORI and excise taxes, see the PCORI Fee and Form 8928 pages.
5
Mandate states
CA, DC, MA, NJ, and RI currently require state-level coverage reporting.
Residency
Drives the obligation
You file based on where covered individuals live, not where the company is based.
Per state
Own portal & format
Each state has a separate portal, file format, and deadline; there's no multi-state filing.
| State | Furnish to Individual | File with State | Notes |
|---|---|---|---|
| Massachusetts (1099-HC) | January 31 | via MassTaxConnect (confirm annual deadline) | Carriers file for fully insured; self-funded employers/TPAs may have separate filing and notice obligations. E-file required regardless of volume. |
| Rhode Island | March 2, 2026 (2025 coverage; follows IRS deadline) | March 31, 2026 | File 1095-B/1095-C data plus a 1094 transmittal via the RI Tax Portal. Confirm current-year instructions from RI Division of Taxation. |
| New Jersey | March 2, 2026 (2025 coverage; follows IRS deadline) | March 31, 2026 | Accepts NJ-1095, 1095-B, or fully completed 1095-C (Parts I & III required). MFT SecureTransport (Axway) for 50+ forms; NJ-1095 form for fewer than 50. No paper filing. NJ does not follow the IRS alternative furnishing method; must send a 1095 to each primary enrollee. |
| California | January 31 | March 31 (automatic extension to May 31) | File federal 1094/1095 forms via FTB MEC FX Portal. E-file required for 10+ returns. Penalty: $50 per covered individual after May 31. |
| District of Columbia | March 2, 2026 (2025 coverage; follows IRS deadline) | April 30, 2026 | File via MyTax.DC.gov. E-file required for all filers; no paper option. File format: pipe-delimited .txt only (XML not accepted). DC's filing deadline is always 30 days after the IRS deadline. |
Massachusetts (1099-HC): Furnish Jan 31; file via MassTaxConnect
Notes: Carriers file for fully insured; self-funded may have separate obligations. E-file required.
Rhode Island: Furnish Mar 2, 2026; file by Mar 31, 2026
Notes: 1095-B/1095-C plus 1094 transmittal via the RI Tax Portal.
New Jersey: Furnish Mar 2, 2026; file by Mar 31, 2026
Notes: NJ-1095, 1095-B, or 1095-C (Parts I & III). Axway for 50+. No alternative furnishing.
California: Furnish Jan 31; file Mar 31 (auto ext. May 31)
Notes: FTB MEC FX Portal. $50 per covered individual penalty after May 31.
District of Columbia: Furnish Mar 2, 2026; file Apr 30, 2026
Notes: MyTax.DC.gov; pipe-delimited .txt only; e-file required for all.
- Employee residency data: Home addresses from payroll or HRIS; identify which employees are residents of CA, DC, MA, NJ, or RI.
- Coverage data by individual: Months of minimum essential coverage per covered individual (same underlying data as your federal 1095s).
- Plan type confirmation: Written confirmation from your carrier or TPA on who will file each state report, especially for NJ, where the employer is on the hook if the insurer fails to file.
- State portal credentials: Register in advance; each state requires its own account setup (FTB MEC FX Portal for CA; MyTax.DC.gov for DC; MassTaxConnect for MA; MFT Axway for NJ; RI Tax Portal for RI).
- Current-year technical specifications: Download each state's file layout before generating your submission; DC requires pipe-delimited .txt; CA requires XML; NJ accepts XML or pipe-delimited .txt via Axway.
1
Identify affected statesPull employee home addresses from payroll. Flag anyone residing in CA, DC, MA, NJ, or RI. If employees live in multiple mandate states, you file separately with each.
2
Confirm who files whatFor fully insured plans, contact your carrier well before the deadline and confirm in writing that they will file each applicable state report. For self-funded plans, confirm with your TPA. You remain responsible if a third party fails to file on time.
3
Register on state portalsIf you haven't filed before, set up portal accounts early; some require approval before you can submit. Don't wait until the week before the deadline.
4
Prepare your data fileExport covered-individual data from payroll/HRIS and format to each state's current technical specifications. Use CA's and NJ's test environments to validate files before the deadline.
5
File and furnishSubmit to each state portal by its deadline; furnish 1095 forms (or 1099-HC for MA) to covered individuals by the applicable individual deadline.
6
Save confirmationsDownload and retain submission receipts, acknowledgment emails, and transmission logs for each state filing immediately; some portals do not retain them long-term.
- California: FTB MEC FX Portal (XML via File Exchange or A2A API). E-file required for 10+ returns. Paper mail to FTB is available for fewer than 10.
- DC: MyTax.DC.gov, pipe-delimited .txt only. Electronic filing required for all filers; no paper option.
- Massachusetts: MassTaxConnect (individual entry, Excel import, or bulk XML). E-file required regardless of volume.
- New Jersey: MFT SecureTransport (Axway) for 50+ forms (XML or pipe-delimited .txt); NJ-1095 form for fewer than 50. No paper option.
- Rhode Island: RI Tax Portal (flat file or online entry). Confirm current specifications from RI Division of Taxation each year.
- Submission receipts and acknowledgment emailsFrom each state portal; download immediately after filing.
- Copies of the data filesSubmitted to each state.
- Carrier/TPA written confirmationShowing they filed on your behalf, including what was filed and when.
- Evidence of furnishing1095 forms (or 1099-HC for MA) to covered individuals by each state's individual deadline.
Common traps
Assuming the carrier handles all state filings: For fully insured plans, the insurer typically files state reports, but not automatically, and not always completely. New Jersey explicitly makes the employer liable if the insurer fails to file. Confirm in writing each year that your carrier will file for each mandate state where you have covered employees.
Filing based on company location instead of employee residency: State mandate obligations are determined by where covered individuals live, not where the company is headquartered. A Texas-based employer with employees living in New Jersey must file with NJ.
NJ alternative furnishing not available: The IRS allows some coverage providers to post a notice rather than proactively send a 1095-B to each enrollee. New Jersey does not follow this option; you must send a 1095 to each primary enrollee regardless of plan size or type.
Wrong file format for DC: DC's MyTax.DC.gov portal accepts pipe-delimited .txt only. XML files are rejected. Generate your DC submission file in the correct format from the start.
FAQs
Does our fully insured carrier file state reports for us?
Usually, but not automatically and not always completely. Contact your carrier before filing season and confirm in writing exactly which states they will file for and by what deadline. If they fail to file, you may be liable. In New Jersey, employer backstop responsibility is explicit in the law.
We're headquartered out of state. Do we still have to file?
Yes. The filing obligation follows employee residency, not employer location. If you have employees who are residents of CA, DC, MA, NJ, or RI, you must file with each applicable state regardless of where your company is based.
What forms do we submit to each state?
Most states reuse your federal 1095 data. California and DC accept 1094-B/1095-B and 1094-C/1095-C in the same format as the IRS. New Jersey accepts NJ-1095, 1095-B, or a fully completed 1095-C (Parts I and III required; Parts I and II only will not be accepted). Massachusetts uses a separate state form, the 1099-HC. Rhode Island accepts 1095-B or 1095-C data through its portal.
How do we identify which employees trigger state filing obligations?
Pull home addresses from payroll or HRIS and filter for CA, DC, MA, NJ, and RI. Do this in Q4; don't rely on general impressions about where your workforce lives. Part-year residents may also trigger obligations depending on the state (see Special Cases).
- California: FTB MEC Information Reporting (portal registration, technical specs, annual deadlines, and penalty information)
- District of Columbia: MyTax.DC.gov (bulk filing portal; pipe-delimited .txt format required for all filers)
- Massachusetts: MassTaxConnect (1099-HC) (portal, bulk XML specifications, and filing instructions for MA coverage reporting)
- New Jersey: Employer Health Coverage Mandate (filing requirements, Axway transmittal instructions, NJ-1095 form and instructions)
- Rhode Island: Health Coverage Mandate Reporting (employer/insurer filing guidance, portal access, and FAQs)
- Multiple mandate states: If employees live in more than one mandate state, you file separately with each. There is no single multi-state submission option; each state has its own portal, format, and deadline.
- Part-year residents: New Jersey requires filing for individuals domiciled in NJ for at least 15 days in any month; part-year residency triggers the full reporting obligation for that individual. DC follows IRS conventions for part-year coverage. Confirm each state's part-year rules before filtering your employee list.
- NJ employer backstop: If a carrier or multiemployer plan fails to file required 1095 forms with New Jersey on time, the employer shares liability and must file itself. Don't assume the filing was completed without verifying each year.
- M&A and entity changes: If a business is acquired or restructured during the year, confirm which entity files state reports for the affected coverage periods, consistent with how the federal 1095s are being handled. Document the decision before year-end.
- CA individual furnishing penalty: California does not impose a state penalty for failure to furnish forms to individuals by January 31, but federal furnishing requirements still apply. The CA $50-per-covered-individual penalty applies only to state filings submitted after May 31.
At-a-glance summary of each mandate state's filing rules. Always verify current-year deadlines with official state sources before submitting.
| State | Who Files | Form(s) | Furnish Deadline | State Filing Deadline | Portal / Format |
|---|---|---|---|---|---|
| California | Employer or carrier (whoever provides MEC) | 1094-B/1095-B or 1094-C/1095-C | January 31 | March 31 (auto ext. May 31) | FTB MEC FX Portal; XML; e-file required for 10+ |
| DC | Employer or carrier (all filers must e-file) | 1094-B/1095-B or 1094-C/1095-C | Follows IRS deadline (Mar 2, 2026 for 2025 coverage) | 30 days after IRS deadline (Apr 30, 2026 for 2025 coverage) | MyTax.DC.gov; pipe-delimited .txt only; e-file required for all |
| Massachusetts | Carrier (fully insured); employer/TPA (self-funded) | Form MA 1099-HC | January 31 | January 31 (confirm with MassTaxConnect annually) | MassTaxConnect; XML or Excel import; e-file required for all |
| New Jersey | Carrier (fully insured); employer (self-funded); employer backstop if carrier fails | NJ-1095, 1095-B, or 1095-C (Parts I & III required) | Follows IRS deadline (Mar 2, 2026 for 2025 coverage) | March 31 | MFT Axway for 50+ forms; NJ-1095 for under 50; no paper |
| Rhode Island | Employer or carrier | 1095-B or 1095-C + 1094 transmittal (reuse federal data) | Follows IRS deadline (Mar 2, 2026 for 2025 coverage) | March 31, 2026 | RI Tax Portal; flat file or online entry |
Specific 2026 dates shown for NJ and DC apply to 2025 coverage year filings. State deadlines shift when IRS deadlines shift. Always confirm with each state's current-year instructions before filing.