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The Wagner Law Group Description 

The Wagner Law Group, A Professional Corporation, is a nationally recognized ERISA & employee benefits, estate planning, employment, labor & human resources practice. 


Established in 1996, The Wagner Law Group has 23 attorneys engaged exclusively in employee benefits, estate planning and employment law. Seven of our attorneys are AV rated by Martindale-Hubbell as having very high to preeminent legal abilities and ethical standards. The firm is among the largest ERISA boutiques in the country. Our practice is national in scope, with clients in more than 40 states and several foreign countries.






Contact Info

The Wagner Law Group


  Integrity | Excellence


Massachusetts Office 

Tel: (617) 357-5200 

Fax: (617) 357-5250 

99 Summer Street 

13th Floor

Boston, MA 02110

Florida Office 

Tel: (561) 293-3590
Fax: (561) 293-3591
7108 Fairway Drive
Suite 125
Palm Beach Gardens, FL 33418


San Francisco Office

Tel: (415) 625-0002

Fax: (415) 358-8300

315 Montgomery Street

Suite 904

San Francisco, CA 94104


Illinois Office

Tel: (847) 250-1365

Fax: (847) 250-1367

414 West Deerpath Road
Lake Forest, IL  60045  







March 20, 2014


 State and Federal Law Alert




 Final Regulations on PPACA's Minimum Essential Coverage Reporting Requirements




The IRS has released final regulations addressing certain reporting and disclosure requirements under the Patient Protection and Affordable Care Act ("PPACA") that are applicable to employers who offer self-insured health coverage to employees.


Background.   PPACA has added significant new reporting requirements to the Internal Revenue Code which enable the IRS to enforce the employer and individual mandates (i.e., the "play-or-pay" provisions) and to administer the premium tax credit. Specifically, Code Section 6055 requires insurers of insured health plans and sponsors of self-funded health plans to file annual information reports with the IRS.


Insurers, and employers sponsoring self-funded health plans, must also furnish an annual statement to individuals enrolled in their plans. This information will be used to determine whether employees qualify for a premium tax credit for coverage purchased through an Exchange.


Information Reporting Requirements. The specific information required to be reported by employers under Section 6055 includes: 

  • information about the employer offering coverage, including contact information;
  • the name and Taxpayer Identification Number ("TIN") of each individual enrolled in the plan; and
  • the months for which the individual was covered. 

An individual's birthdate may be used in place of a TIN if, after reasonable efforts, the employer cannot obtain the TIN from the individual.


Consolidated Reporting Permitted. The final regulations provide for a single consolidated form that employers can use to report to the IRS and employees under Code Sections 6055 and 6056 and thereby avoid duplicative reporting. (See the 3/13/2014 Alert for information on the Section 6056 reporting requirements.) The combined form will have two sections: the top half for Section 6056 reporting, and the bottom half for Section 6055 reporting.


Employers subject to PPACA's shared responsibility provisions (i.e., employers with 50 or more full-time equivalent employees) and who self-insure will complete both the top and bottom portions of the form. Employers that provide health coverage via insurance contracts will complete only the top half of the form.


Effective Date. The Section 6055 reporting requirements are effective for coverage provided on or after January 1, 2015, with the first information return to be filed with the IRS and provided to individuals in early 2016. 





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Pursuant to Internal Revenue Service Circular 230, we hereby inform you that any advice set forth herein with respect to US federal tax issues is not intended or written by The Wagner Law Group to be used and cannot be used, by you or any taxpayer, for the purpose of avoiding penalties that may be imposed on you or any other person under the Internal Revenue Code.


This Newsletter is provided for information purposes by The Wagner Law Group to clients and others who may be interested in the subject matter, and may not be relied upon as specific legal advice.  This material is not to be construed as legal advice or legal opinions on specific facts. Under the Rules of the Supreme Judicial Court of Massachusetts, this material may be considered advertising.