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NJ Health Insurance Mandate

Guidance for Health Coverage Filings (1094/1095)

Starting with Tax Year 2019, the New Jersey Legislature requires third-party reporting to verify health coverage information supplied by individual Income Tax payers. Employers and all other providers of Minimum Essential Coverage to New Jersey residents must send health-care coverage returns to the State for the 2019 Tax Year. Filers will transmit coverage returns through New Jersey’s system for processing W-2 forms.

Coverage returns will contain the information specified by federal Internal Revenue Service (IRS) rules and regulations for 1094 and 1095 filings. Companies are encouraged to send data pertaining only to New Jersey full-year and part-year residents. However, for ease of filing, 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. Out-of-state filers who provide information on non-residents of New Jersey should consult privacy and other laws pertaining to residents of other States before sending any sensitive or personal data to New Jersey. Filers must provide 2019 coverage information electronically by March 31, 2020.

The State expects filings of Form 1094-CTransmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, and Form 1095-CEmployer-Provided Health Insurance Offer and Coverage. 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, substantially alters, or makes unavailable Forms 1095-A, 1094-B, 1094-C, 1095-B, or 1095-C, New Jersey will deploy similar forms and require they be sent to the State and to New Jersey taxpayers. Check this website for reporting updates.

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. If you are an out-of-State employer, you must ensure that we receive any required 1095 document for each New Jersey resident you employ. Insurers, government agencies, multiemployer plans, and all others responsible for reporting Minimum Essential Coverage to New Jersey residents also must file the required information with the State.

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 that employed an average of at least 50 full-time-equivalent employees on business days during the preceding calendar year. 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 that employed an average of fewer than 50 full-time equivalent employees on business days during the preceding calendar year. Health coverage provider (the insurer) files 1095-B for each covered member of the plan. Employer does not file a 1095-C.
  • Fully Insured Employer Participating in a Multiemployer Plan. 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).  ALEs generally are companies that employed an average of at least 50 or more full-time equivalent employees on business days during the preceding calendar year: Employer files 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. ALE members that offer employer-sponsored, self-insured health coverage to non-employees may use Forms 1094-B and 1095-B for these non-employees, or ALEs may file a 1095-C using Code 1G in Part II, to report for non-employees. 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 that employed an average of fewer than 50 full-time equivalent employees on business days during the preceding calendar year. Employer files a 1095-B for each covered employee.
  • Self-Insured Employer Participating in a Multiemployer Plan. Plan sponsor (generally a board of trustees) files 1095-B for each covered employee. Applicable Large Employers also file Parts I and II of 1095-C for each covered employee.

Under New Jersey’s Health Insurance Market Preservation Act, insurers, self-insured employers, government agencies, multiemployer plans and other entities that provide health insurance must submit information returns to New Jersey reporting on individuals’ health insurance coverage. There is no paper filing option available.

Insurers or Employers are able to provide confidential or sensitive data to the State of New Jersey using the Division of Revenue and Enterprise Services' (DORES) MFT SecureTransport service.

Taxpayers who have MFT SecureTransport service user credentials can now use them to submit the required health insurance coverage returns.

If you do not have an MFT SecureTransport service account or need technical specifications, you can request the information by contacting e-GovServices@treas.nj.gov.

Once DORES receives your request and authorizes your account, you can expect to receive instructions on how to submit your health insurance coverage returns.

New Jersey will accept returns submitted in bulk filing.  A company responsible for submitting files for multiple companies can establish a single MFT SecureTransport Account and submit a single file containing the information for the various companies. We will not accept files in a zipped file format.

You will receive a submission receipt upon successful transmission which will serve as the acknowledgement. This receipt will be sent to the email associated with the MFT SecureTransport Account.

If you are required to submit a correction file to the IRS, New Jersey will also require you to submit the correction file.

XML Schemas and other information for transmitters are provided by tax year:

2019 Tax Year will accept 1095A, 1094-B, 1094-C, 1095-B, and 1095-C

Testing Period

We strongly encourage you to participate during our testing period, which will run from July 1, 2019, through September 1, 2019. Test scenarios are available.

You can submit a request here to participate in our testing.


Under the federal Affordable Care Act, adult children up to age 26 may be covered by their parents’ health plan.

NJHIMPA does not require Forms 1095-B or 1095-C be provided separately to children covered by their parents’ health plans. This applies regardless of their residency, beyond the requirement under 26 U.S.C. s.6055, as that section was in effect and interpreted on December 15, 2017.

It is recommended that employers advise employees to provide a copy of any Form 1095-B or 1095-C containing coverage information to their children residing in New Jersey.


Last Updated: Thursday, 07/25/19