The Rhode Island Division of Taxation recently released guidance on their state individual mandate reporting requirements. As a reminder, the Rhode Island individual mandate (“RI Mandate”) requires Rhode Island residents to maintain “minimum essential health care coverage” beginning January 1, 2020, or pay a tax penalty.

All employers (including out-of-state employers) who provide employment-based health care coverage to any resident of Rhode Island, must do the following (or work with their carrier or vendor to do the following):

  1. Distribute IRS Forms 1095-B/C to Rhode Island plan participants by January 31st; and
  2. Submit IRS Forms 1095-B/C to the Rhode Island Division of Taxation (DOT) by January 31st.

For 2020 calendar year reporting only, the DOT extended the distribution deadline to March 2, 2021 and the reporting deadline to March 31, 2021, to mirror the federal Affordable Care Act (ACA) distribution and reporting deadlines.

Which employers are subject to RI Mandate reporting and distribution requirements?

Employers who offered employment-based healthcare coverage to Rhode Island residents are subject to the distribution and reporting obligations.

  • Fully insured employers: Employers are not required to complete the distribution or reporting if their carrier handles those requirements. Carriers licensed or otherwise authorized by the Rhode Island Office of Health Insurance Commissioner to offer health coverage are required to distribute forms and report. Therefore, out-of-state employers with fully insured plans should check with their carrier to determine whether they will complete the RI Mandate distribution and reporting.
  • Self-insured employers: Employers who offered coverage through a self-insured plan to Rhode Island residents are subject to the distribution and reporting obligations. These employers may want to work with their ACA reporting vendor to complete these obligations.

How do employers complete the reporting?

Employers must submit copies of their ACA reporting (IRS Forms 1095-B/C that were prepared for Rhode Island employees) to the Rhode Island Division of Taxation. The Division of Taxation will provide a webpage where employers can upload the forms. A link to the webpage will be available on the Division of Taxation’s website.

What are the distribution and reporting deadlines?

The deadline to distribute forms and report to the DOT is January 31st following the end of the applicable calendar year. It is important to note that this state deadline is earlier than the federal Affordable Care Act reporting deadline, which is typically February 28th for paper filing and March 31st for electronic filing.

For 2020 reporting only, the DOT is extending the distribution deadline to March 2, 2021 and the reporting deadline to March 31, 2021 (these are the same deadlines as federal ACA reporting).

Employer Action Items:

  • Fully insured employers should check with their carrier to see whether they will complete the RI Mandate distribution and reporting obligations.
  • Self-insured employers may want to work with their ACA reporting vendor to complete the distribution and reporting obligations. Employers can also complete the reporting by submitting 1095 forms through the DOT website.

Additional Resources:

Disclaimer: This content is intended for informational purposes only and should not be construed as legal, medical or tax advice. It provides general information and is not intended to encompass all compliance and legal obligations that may be applicable. This information and any questions as to your specific circumstances should be reviewed with your respective legal counsel and/or tax advisor as we do not provide legal or tax advice. Please note that this information may be subject to change based on legislative changes. © 2020 Sequoia Benefits & Insurance Services, LLC. All Rights Reserved

Emerald Law – Emerald is a Client Compliance Consultant for Sequoia, where she works with our clients to optimize and streamline benefits compliance. In her free time, Emerald enjoys stand-up comedy, live music and writing non-fiction.