New Jersey Employer Reporting for Tax Year 2019

by David Mordo
New Jersey Employer Reporting for Tax Year 2019

As a result of the New Jersey Individual Mandate that became effective 1/1/2019, the New Jersey Legislature requires third-party reporting to verify health coverage information supplied by individual income taxpayers. Employers and all providers of Minimum Essential Coverage (MEC) to New Jersey residents will be required to send healthcare coverage returns for the 2019 Tax Year.

Coverage returns will contain the information specified by the Internal Revenue Service (IRS) rules and regulations for 1094 and 1095 filings. New Jersey will accept the same 1094/1095 data files sent to the IRS, even if they include data about individuals who are not residents of New Jersey. The filing of information must be done electronically by March 31, 2020.

The forms expected to be filed are:

  • Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
  • Form 1095-C, Employer-Provided Health Insurance Offer and Coverage
  • Form 1094-B, Transmittal of Health Coverage Information Returns
  • Form 1095-B, Health Coverage, should use those forms for New Jersey filings

The specific requirement for filing is dependentĀ on whether your employer group is fully insured or self-insured, as well as the size of your employer group. Use the guide below for assistance.

Fully Insured

  • Single-Company, Applicable Large Employers (ALEs)
    • The health coverage provider (insurer) files 1095-B for each covered member of the plan. The 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)
    • The health coverage provider (insurer) files 1095-B for each covered member of the plan. The employer does not file a 1095-C.
  • Fully Insured Employer Participating in a Multiemployer Plan
    • The plan sponsor (generally a board of trustees) files 1095-B for enrolled individuals. Applicable Large Employers also file 1095-C (Parts I and II) for each person who was a full-time employee for at least one month of the calendar year.

Self-Insured

  • Single-Company, Applicable Large Employers (ALEs)
    • The employer files a 1095-C for each person who was a full-time employee for at least one month of the calendar year and for any employee who was enrolled in the self-insured plan.
  • Single Company, Not an Applicable Large Employer (Non-ALE)
    • Employer files a 1095-B for each covered employee.
  • Self-Insured Employer Participating in a Multiemployer Plan
    • The plan sponsor (generally a board of trustees) files a 1095-B for each covered employee. Applicable Large Employers also file Parts I and II of 1095-C for each covered employee.

Out-of-State Employers of New Jersey Residents
Out-of-state employers who employ New Jersey residents have the same filing requirements as in-state businesses. These requirements are not limited to businesses that withhold New Jersey payroll taxes. Out-of-state employers must ensure that 1095 documentation is received for each New Jersey resident that is employed. All insurers, government agencies, multiemployer plans, and others responsible for reporting Minimum Essential Coverage to New Jersey residents also must file the required information with the state.

For more information or questions concerning the New Jersey Employer Reporting requirements please contact David Mordo at
david.mordo@benefitmall.com.

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