By Yana Lender
2020 was a year of surprises for all of us – our health, economy, politics, and personal and professional lives were turned upside down. What always remains consistent, though, in any circumstances, is taxes. The IRS might change filing requirements and deadlines, but we can be sure that taxes will always be there.
Affordable Care Act filing requirements on the Federal level have not changed much. Deadlines were extended (thankfully for your filing vendor or for you if you are doing it for your organization); however, to make sure it was not as easy as 1-2-3, ICHRAs (Individual Coverage HRAs) were thrown into the mix. And of course, in addition to the State of NJ and District of Columbia, Rhode Island and California have officially requested state filing of 1095-C forms for 2020.
State filing should be easy and should logically follow the same cadence/requirements as the Federal 1095-C process. “Should” is the keyword, and no, none of the currently active states have the same requirements, deadlines, or filing methods. Fortunately, if you have a compliance partner like us, it is our job to alleviate the burden of figuring it all out. Unfortunately, it only helps those organizations that have self-insured plans. What all states have in common is that the burden falls on the filer (organization/vendor) if the organization is self-insured, and on the coverage provider/multi-employer if the organization is fully insured or has union employees.
What we have learned from a few of our fully insured clients is that some coverage providers interpreted state requirements in such a way that state filing was deemed to not be their concern. That decision put the burden of state reporting on our clients, sending them scrambling to file in time. Luckily with Paragon as their Federal ACA Compliance partner, they knew they could turn to us for advice and a possible solution. The good news is that we were able to find a short-term solution to help those who reached out to us to file with each state. We are working to offer state reporting to fully insured clients and non-clients for 2021 and would love your input.
With ACA here to stay for a while, we think more states will be jumping on the bandwagon of state filing and we also think more coverage providers will pull away from doing their required part, pawning it off on you, fully insured organizations. We want to help as much as we can. If you are not sure whether your state filings were done for 2020, contact your provider right away and ask for confirmation. If they cannot provide you a confirmation or if they tell you it was not done, contact us! We want to explore how we can help you.
CONTACT US HERE to let us know if you are interested in state filing services or to find out how we can help with your 2020 state filings.