Tom Hospod
September 27, 2019

Washington DC enacted a health insurance individual mandate, to go into effect for Tax Year 2019. Reporting will begin in 2020, with the first reports due on June 30, 2020 for Tax Year 2019.

The Office of Taxation and Revenue (OTR) has published a notice explaining details regarding its implementation.

Under the mandate, most District taxpayers must maintain qualifying health coverage, get an exemption, or pay a penalty. The law also requires every employer or other sponsor of an employment-based health plan and insurance issuers, including the District of Columbia Department of Healthcare Finance (DHCF), to submit an information return to OTR regarding coverage offered and provided to individuals as well as to furnish a statement to the individual covered.

Forms 1095-B or 1095-C will be used to furnish an annual statement of health coverage to employees or covered individuals. Applicable entities should file the same information returns that they file with the IRS, including: Forms 1094-B, 1095-B, 1094-C, and 1095-C. All information returns must be filed electronically with OTR through using OTR’s specifications. All files must be a delimited file with an extension of .txt (.zip files are acceptable).

For tax year ending December 31, 2019, the deadline is June 30, 2020. For tax years beginning after December 31, 2019, the deadline is 30 days after the IRS deadline for submitting 1095-B or 1095-C forms, including any extensions granted by the IRS

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Tom Hospod

Tom Hospod is a Regulatory Counsel at Sovos Compliance. Within Sovos’ Regulatory Analysis function, Tom focuses om Affordable Care Act (ACA) reporting, Tax Withholding, and Automatic Exchange of Information (AEOI). Prior to Sovos, Tom worked as a legislative aide in the Massachusetts House of Representatives. Tom is a member of the Massachusetts Bar, earned his B.A. from Boston College and his J.D. from the University of Miami.
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