IF YOU HAVE SELF-INSURED PLANS, PLEASE READ THE INFORMATION BELOW:
States requiring 1095-C filing for state residents follow a similar pattern to federal filings. We have reviewed each state’s guidance to provide you with specific actions you need to take regarding multiemployer arrangements. Paragon Compliance will satisfy ALL state filing requirements they relate to your Self-Insured plan for enrollees residing in the various states requiring filings. All required 1095-C filings will be submitted pursuant to the individual state’s requirements.
These requirements also affect self-insured employers participating in a multiemployer plan. If you have a multiemployer arrangement, we suggest you do the following:
Understand that an employer may share liability if its multiemployer plan does not file the required 1095 forms on time.
New Jersey in particular has guidance that states that, “an employer may share liability if its multiemployer plan does not file the required 1095 forms on time. According to regulations now being finalized, there is a penalty of $50 per form for failure to file as required, up to $50,000 per insurer, employer, or other coverage provider. Insurers and multiemployer plans generally file 1095s for fully-insured employers. We strongly recommend contacting your multiemployer plan well in advance of the March 31 filing deadline to ensure that 1095 forms will be filed with the State of New Jersey.”
By following our suggested steps, you can mitigate this potential shared liability if the insurer fails to file with the state by the appropriate deadline.
*Please keep this statement for your records*
FULLY-INSURED PLANS PLEASE READ THE INFORMATION BELOW:
In general, each state provides specifics on the requirements for state filings as it relates to employees receiving 1095-C and 1095-B forms from employers and insurers. We have reviewed the information to provide you with specific actions you need to take to ensure that your required state filings are satisfied.
Coverage providers must:
These requirements to file affect Fully-Insured Health Providers which include Applicable Large Employers and Fully-Insured Employers participating in a Multiemployer Plan. However, based on the guidance provided, fully-insured employers should expect filings to be done by their insurance carrier. We suggest you do the following:
New Jersey in particular has guidance that states that, “an employer may share liability if its insurer or multiemployer plan does not file the required 1095 forms on time. According to regulations now being finalized, there is a penalty of $50 per form for failure to file as required, up to $50,000 per insurer, employer, or other coverage provider. Insurers and multiemployer plans generally file 1095s for fully-insured employers. However, the employer does not eliminate its filing responsibility if an insurer declines to file 1095 forms on behalf of a fully-insured employer. We strongly recommend contacting your insurer or multiemployer plan well in advance of the March 31 filing deadline to ensure that 1095 forms will be filed with the State of New Jersey.”
FOR SELF-INSURED PLANS PLEASE READ THE INFORMATION BELOW:
FOR FULLY-INSURED PLANS PLEASE READ THE INFORMATION BELOW:
*Please keep these statements for your records*
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