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NJ Health Insurance Mandate – Information for Employers

May 6, 2019

The following information is directly from the Official Site of The State of New Jersey

Starting with Tax Year 2019, the New Jersey Legislature requires third-party reporting to verify health coverage information provided by individual taxpayers. That means employers must provide New Jersey taxpayers and the State with the same 1094 and 1095 health-care coverage information they sent to the IRS in Tax Year 2018. Employers will file health coverage forms through New Jersey’s system for filing of W-2 forms. Companies must file 2019 coverage information electronically by February 15, 2020. We will post instructions on this website in mid-2019.

The State expects Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, and Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, from employers who filed these forms federally in 2018. Filers of Form 1094-B, Transmittal of Health Coverage Information Returns, and Form 1095-B, Health Coverage, should use those forms for New Jersey filings.

If the federal government discontinues or substantially alters Forms 1094-B, 1094-C, 1095-B, or 1095-C, New Jersey will deploy similar forms and require that they be sent to the State and to New Jersey taxpayers. Check this website periodically for reporting updates.

Out-of-State Employers of New Jersey Residents:

Out-of-State employers that withhold and remit New Jersey Gross Income Tax for New Jersey residents have the same filing requirements as businesses located in New Jersey.

Guidance on Forms Sent to New Jersey:

Requirements for these filings vary depending on whether an employer is fully insured, self-insured, or a participant in a multiemployer plan. The size of a company also affects reporting requirements, as detailed below:

Fully Insured:

Single-Company, Applicable Large Employers (ALEs). ALEs generally are companies with 50 or more employees:

Health coverage provider (the insurer) files 1095-B for each covered member of the plan. Employer files 1095-C (Parts I and II) for each person who was a full-time employee of the employer for at least one month of the calendar year.

Single-Company, Not an Applicable Large Employer (Non-ALE). Non-ALEs generally are companies with fewer than 50 employees:

Health coverage provider files 1094-B. Employer does not file a 1095-C.

Any Fully Insured Employer Participating in a Multiemployer Plan:

Plan sponsor (generally a board of trustees) files 1095-B for enrolled individuals. Employer files Parts I and II of 1095-C for each employee.

Self-Insured:

Single-Company, Applicable Large Employers (ALEs).  ALEs generally are companies with 50 or more employees:

Employer files 1095-C for each person who was a full-time employee of the employer for at least one month of the calendar year. Employer fills out Parts I and II of 1095-C for part-time employees. ALE members that offer employer-sponsored, self-insured health coverage to non-employees who enroll may use Forms 1094-B and 1095-B, rather than Form 1095-C, Part III, to report coverage for those individuals and other family members. For this purpose, a non-employee includes a non-employee director, an individual who was a retired employee during the entire year, or a non-employee COBRA beneficiary. This also applies to a former employee who terminated employment during a previous year.

Single Company, not an Applicable Large Employer (Non-ALE). Non-ALEs generally are companies with fewer than 50 employees:

Employer files a 1095-B for each covered employee.

Any Self-Insured Employer Participating in a Multi-employer Plan:

Plan sponsor (generally a board of trustees) files 1095-B for each covered employee. Employer files Parts I and II of 1095-C for each covered employee.

 

For more information regarding Employee Benefits for your organization, or to speak with one of our advisors, email Jason Della Penna, Executive Vice President at Brown & Brown Benefit Advisors at jdellapenna@advisorsbb.com.

“This content is strictly informational and should not be used as specific advice on insurance products, legal, accounting and/or tax related matters. Insureds should always contact the appropriate licensed professional for their insurance, legal, accounting or tax needs.”


Brown & Brown Benefit Advisors