Second Opinions

SECOND OPINIONS: ACA Employer Reporting Requirements – Part I

February 5, 2014 (PLANSPONSOR.com) – In this column and a later column, experts from Groom Law Group answer some of the frequently asked questions received about the large employer, employer mandate reporting obligations under Code section 6056.

By PS | February 05, 2014
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Code section 6056, as enacted by the Patient Protection and Affordable Care Act (ACA), requires “applicable large employers” subject to the employer “shared responsibility” mandate (Code section 4980H) to report to the Internal Revenue Service (IRS) information about their compliance with the  mandate and any health care coverage offered to employees. 

Section 6056 also requires those employers to furnish related statements to employees so that the employees may use the statements to help determine eligibility for the ACA premium tax credit.  A similar reporting requirement in Code section 6055 requires health insurance issuers and employers that sponsor self-insured plans to report and provide statements on minimum essential coverage offered under their plans.

On July 2, 2013, the Department of Treasury announced it was issuing transition relief to delay the implementation date of the Code section 6055 and 6056 information reporting provisions and the employer mandate requirements from 2014 until 2015. The IRS subsequently issued Notice 2013-45 formalizing the transition relief and delayed implementation date.  On September 9, 2013, the Department of the Treasury and IRS published proposed regulations on the Code section 6055 (78 Fed. Reg. 54986) and section 6056 (78 Fed. Reg. 54996) reporting requirements.  It is likely that final regulations on these ACA reporting requirements will be published later this year.

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