Home Understanding D.C. Health Insurance Mandate

What is the D.C. Individual Responsibility Requirement?

The District of Columbia (D.C.) requires that all D.C. residents have minimum essential coverage (MEC), have an exemption, or pay a penalty. Additionally, it requires that every applicable entity providing MEC to an individual must submit an information return to the D.C. Office of Tax and Revenue and provide a statement regarding the coverage to the individual.

ACA filing requirements

Applicable Entities

An applicable entity is any employer or other sponsor of an employment-based health plan, or an insurance issuer. These include the following:

  • All employers who sponsor self-insured group health plans that cover one or more employees that were D.C. residents
  • Employers or other sponsors of fully-insured employment-based health plans that covered fifty or more full-time employees, including at least one D.C. resident
  • Persons/entities who provided MEC to a D.C. resident
  • An insurance issuer or carrier licensed/authorized to offer MEC in D.C.

D.C. Residents

For purposes of reporting D.C. health insurance coverage, an individual is a D.C. resident if any of the following apply:

  • For employers (or sponsors of employment-based plans) - the person is an employee whose wages were withheld and paid to D.C. during the relevant calendar year.
  • For entities that provided MEC - the individual had a home or mailing address in D.C. at any time during the relevant calendar year
  • For insurance issuers/carriers that provided MEC - the individual had a home or mailing address in D.C. at any time during the relevant calendar year
ALE explained

What forms must be filed with D.C.?

The same information that is filed with the IRS must be filed with D.C. This includes the following forms:

  • Form 1094-B, Transmittal of Health Coverage Information Returns
  • Form 1095-B, Health Coverage
  • Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
  • Form 1095-C, Employer-Provided Health Insurance Offer and Coverage

B Series

Filed by:

  • Insurance companies
  • Employers that offer coverage on a self-funded plan with less than 50 full-time + full-time equivalent employees

Consists of:

Form 1094-B
1 per Issuer
Form 1095-B
1 per Responsible Individual

A 1094-B and its 1095-Bs MUST be filed together

C Series

Filed by:

  • Employers that offer coverage to at least 50 full-time + full-time equivalent employees
  • Includes employers with self-funded, fully-funded, ICHRA, and union-based plans

Consists of:

Form 1094-C
1 per Applicable Large Employer (ALE)
Form 1095-C
1 per Eligible Employee

A 1094-C and its 1095-Cs MUST be filed together

How can employers file with D.C.?

All filings must be submitted electronically through MyTaxDC.

Paper filings are not accepted.

What are the ACA deadlines for D.C.?

Deadlines for D.C. ACA filings are as follows:

  • The deadline to furnish forms to recipients is March 2nd
  • The deadline to file your D.C. ACA forms is April 30th
D.C. filing formats

Do filers need to remove non-D.C. residents from their submissions?

No, the OTR accepts the same ACA data that is filed with the IRS. However, if a filer chooses to remove data on non-D.C. residents, they must also submit an updated transmittal (Form 1094-B or Form 1094-C) along with their 1095 data.

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