Rhode Island Employer Health Coverage Reporting

November 23, 2020

Rhode Island, requires all residents of the state to be enrolled in qualifying health coverage and maintain minimum essential coverage (MEC).


As of January 1, 2020 Rhode Island, requires all residents of the state to be enrolled in qualifying health coverage. Failure of an individual to maintain coverage will result in a penalty unless the individual has qualified for an exemption. One of the components of the Rhode Island Health Coverage Mandate is third-party reporting to verify whether applicable Rhode Island residents maintain minimum essential coverage (MEC).

Health Coverage Reporting

Certain employers that offer employer-sponsored health coverage and other entities that provide health coverage are required to file minimum essential coverage (MEC) information to the Rhode Island Division of Taxation. Employers of Rhode Island residents can use the same federal forms 1094 and 1095 filed with the IRS to transmit MEC coverage information to the state of Rhode Island.

Out-of-State employers that employ Rhode Island residents have the same filing requirements as In-State businesses.

The state will accept the IRS ACA AIRS reporting format and will provide portal access on the Division of Taxation website to file the returns at a future date.  For tax year 2020 only the filing deadline is March 31, 2021. In future years the filing deadline will be January 31.

Paylocity will provide third-party reporting provider in the Rhode Island Health Coverage Reporting Program for our ALE clients utilizing ACA Enhanced and Essentials if the company has one or more employees that had a home address in Rhode Island for all or part of the 2020 calendar year. This includes:

If Fully Insured Applicable Large Employer (ALE):

  • An employee who has and / or had a home residence state of Rhode Island in any month of calendar year 2020 and
  • An employee considered a full-time employee for one or more months (under ACA rules – averaged 30 or more hours per week) and
  • An employee who receives a Federal W-2 (not necessarily Rhode Island wage/tax reported).

If Self-Insured ALE, also include the following in addition to above:

  • Any individual enrolled in coverage, including individuals enrolled in the employer plan that are part-time employees as well as individuals enrolled in coverage that are not W-2 employees.

This includes:

  • 1099
  • K1
  • Retirees
  • Non-employee/former employee COBRA participants
  • Paylocity does not include employees in the Rhode Island file that do not meet this criterion.
    Paylocity will only include Rhode Island employees for multi-state companies.

Thank you for choosing Paylocity as your Payroll Tax and HCM partner. This information is provided as a courtesy, may change and is not intended as legal or tax guidance. Employers with questions or concerns outside the scope of a Payroll Service Provider are encouraged to seek the advice of a qualified CPA, Tax Attorney or Advisor.