NJ Shared Responsibility Payments

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mggray17
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Joined: Thu Feb 11, 2010 7:09 am

NJ Shared Responsibility Payments

Post by mggray17 »

Hoping that someone familiar with NJ Taxes can provide help here.

A friend who was out of the workforce prior to Jan 2022, started a new job in NJ in January 2022.
This job had a 90 day waiting period for healthcare for an "Applicable Large Employer", thus the 1095-C has 4980H Safe Harbor Code of 2D for Jan, Feb and March of 2022.

Code 2D is: Employee in a section 4980H(b) Limited Non-Assessment Period. Employee in a waiting
period, initial measurement period, initial administrative period, or other limited non-assessment period.

This 1095-C shows full coverage for April through Aug.

They worked in this job until mid August, and then left for a better opportunity. They gave notice, and when the agreed upon date came, left job 1 and started job 2 the next day. Job 2 also had a healthcare waiting period so the 1095-C shows coverage for Nov and Dec.

So the question is will the health coverage waiting periods translate to a NJ SRP Exemption for those months?

NJ doesn't seem to provide for this as an exemption, even though this person was in the workforce for all 12 months of the year and was "Playing by the rules" so to speak to receive the health coverage provided by each employer.

The only thing that seems applicable is the "Short Gap in Coverage" exemption, but it says it can't be used for both gaps (must used in the first gap) and there wasn't coverage in Dec 21 so not sure they would accept that either.

Thanks for any insight.
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