New Jersey Enacts Individual Mandate, Effective Date Approaches

Following the lead taken by Massachusetts, New Jersey is now the second state to enact a state level 'individual mandate'. The law tracks the requirements of the formerly effective Affordable Care Act individual mandate (which was reduced to $0 for 2019). Though this is an individual mandate with a penalty for noncompliance on individuals only, employers are required to supply the necessary information for the state to enforce the law. Accordingly, under the New Jersey law, employers will need to report on coverage for their employees beginning in 2020, and base the reporting on the 2019 calendar year. The presently applicable IRS 1094-C and 1095-C forms will be utilized for the New Jersey law as well.

Any employer that pays an employee on a New Jersey W2 will need to comply with the reporting under the law. The New Jersey state website has some helpful information here. Employers will use the state's current W2 filing system (here) to file information about their employees' health insurance enrollment.

Employers should speak with their payroll vendors, or work with internal payroll departments ahead of the January 2020 reporting deadline to ensure all necessary information will be ready.