By Tulay Turan, J.D.
The ERISA Industry Committee (ERIC) has submitted comments to the IRS on proposed regulations regarding reporting requirements for large employers that offer group health plans to employees and their families.
The proposed regulations govern how large employers must demonstrate to the IRS that they offer affordable health insurance to employees, or else employers must pay steep fines levied under the Affordable Care Act (ACA).
Among other things, the proposed rules recommend modifications to the Taxpayer Identification Number (TIN) solicitation rules under Code Sec. 6724. The proposed regulations would require Reporting Entities to conduct three solicitations for missing and/or incorrect TINs.
"While we appreciate the government’s attempt to create special TIN solicitation rules for the purposes of Code section 6055 reporting, we do not believe the proposed regulations create a straightforward and workable system under which plan sponsors can collect and report the relevant information to IRS," ERIC wrote.
Comments. ERIC’s comments on the proposed regulations include the following:
modify the Code Sec. 6724 regulations directly;
permit TIN solicitations at the plan level;
clarify the effective date;
provide additional transition relief; and
"ERIC members offer health insurance plans that cover millions of employees and their families, making it difficult for them, as plan sponsors, to keep up with ever-changing and ever-growing compliance and reporting requirements at the federal and state level. It is imperative that any new rules lessen the already enormous administrative burden large employers are under," said James Gelfand, senior vice president of health policy, ERIC. "The IRS should craft the rules in a way that makes sense for plan sponsors, such as allowing quarterly solicitation of information from plan beneficiaries."
Companies: The ERISA Industry Committee
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