New Jersey Shared Responsibility Reporting

Effective for Tax Year 2019, New Jersey’s 1095 compliance requirements for their individual state mandate will take effect. Employers sitused in New Jersey or who employ New Jersey residents must now comply with these requirements by sending the 1095 forms to the New Jersey government using the same system for filing W-2 paperwork: the MFT SecureTransport system.

Employers and other coverage providers must send this information to the State for processing on or before March 31, 2020. Currently, no extensions are available. The deadline to send these forms to primary enrollees is March 2, 2020.

Employers are expected to send either form 1095-C or 1095-B. Employers or Insurers can send a 1095-C form in addition to or in lieu of the 1095-B form. Currently, the 1094 forms are not required but will be accepted if they are sent with the 1095. New Jersey requires only Parts I and III of Form 1095-C be completed but will accept fully completed forms as well.

Several payroll companies and third-party administrators file these forms on behalf of their clients, but not all. It is suggested employers check with their vendor to ensure they are filing the appropriate forms.

This chart: Federal, NJ and Member-Level Reporting provides a brief outline on the filing requirements by employer size and coverage type.

*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.

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