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Tuesday, May 15, 2012

As we have posted about previously, the IRS has requested comments on the determination of “minimum value” (discussed here) and reporting on “minimum essential coverage” (discussed here).  In this, our final post of the series, we summarize the IRS’s request for comments regarding reporting by employers subject to “play or pay” penalties in Notice 2012-33.

Beginning in 2014, employers who could be subject to PPACA’s “pay or play” penalties must file returns with the IRS that include the following information:

  • Name and EIN;
  • The date the return is filed;
  • A certification of whether the applicable large employer offers its full-time employees (and their dependents) the opportunity to enroll in minimum essential coverage under an eligible employer-sponsored plan;
  • If so, a certification of:
    • The duration of any waiting period;
    • The months during the calendar year when coverage under the plan was available;
    • The monthly premium for the lowest cost option in each enrollment category under the plan; and
    • The employer’s share of the total allowed costs of benefits provided under the plan.
  • The number of full-time employees for each month of the calendar year;
  • For each full-time employee, the name, address, and taxpayer identification number (TIN) of the employee and the months (if any) during which the full-time employee (or any dependents) were covered under the eligible employer-sponsored plan; and
  • Such other information as may be required by the Secretary of the Treasury.

Companion returns with the above information (except EIN) and employer address and contact information must be provided to full-time employees.

The IRS has requested comments on how to minimize the reporting burden and coordinate. In view of the substantial overlap between this reporting and the minimum essential coverage reporting, it makes sense that the IRS would want to try to coordinate the two reporting requirements.

Comments are due by June 11. (You can also leave us a comment in the fields below, but we won’t promise the IRS will read it.)

Related Links

Prior Post on Determination of Minimum Value

Prior Post on Minimum Essential Coverage Reporting

Other Health Reform Posts

Disclaimer/IRS Circular 230 Notice


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