The Wagner Law Group Description
Wagner Law Group, A Professional Corporation, is a nationally
recognized ERISA & employee benefits, estate planning,
employment, labor & human resources practice.
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.
Wagner Law Group
Fax: (561) 293-3591
7108 Fairway Drive
Palm Beach Gardens, FL 33418
Francisco, CA 94104
West Deerpath Road
Forest, IL 60045
March 13, 2014
State and Federal Law
Regulations on PPACA's Large Employer Reporting Requirements
The IRS has
released final regulations addressing certain reporting and
disclosure requirements applicable to employers under the Patient
Protection and Affordable Care Act ("PPACA").
significant new reporting requirements to the Internal Revenue Code
to enable the IRS to enforce the individual and employer shared
responsibility provisions (i.e., the "play-or-pay"
provisions) and to administer the premium tax credit. Specifically,
Code Section 6056 requires large employers (i.e., employers
with at least 50 full-time equivalent employees) to: (i) report
information to the IRS about the health care coverage provided to
full-time employees, and (ii) furnish a statement to each full-time
employee which will be used to determine eligibility for the premium
Below is a
highlight of the major provisions contained in the regulations:
- Required Content: Large employers must report: the length
of any waiting period for the group health plan; whether the
employer offers its full-time employees, and their dependents,
the opportunity to enroll in minimum essential coverage under
the plan; the monthly premium for the lowest cost plan option;
and, any month during which no employees were either: (i)
providing services; or (ii) being credited with hours of service.
- Electronic Filing: Employers that file more than 250 Section
6056 returns during the year must file electronically. (Each
Section 6056 return for a full-time employee is counted as a
separate return.) Employers may also furnish the statements to
employees electronically, if certain requirements are met.
- Due Dates: Annual Section 6056 returns must be filed
with the IRS by February 28 (or March 31, if electronically
filed) of the year following the year to which the return
relates. Section 6056 employee statements must be furnished by
January 31 of the year following the year to which the
statements relate. The IRS declined to provide alternate filing
dates for employers that sponsor non-calendar-year plans.
- Third Party Assistance: Large employers may generally contract
with third party administrators for assistance in filing returns
and furnishing employee statements under Section 6056. However,
these third party arrangements do not absolve employers from
potential liability for failing to report or furnish employee
statements under Section 6056.
- Penalties: Large employers that fail to comply with
Section 6056 reporting requirements are subject to penalties.
However, the IRS is providing limited penalty relief for
entities that can demonstrate good faith efforts to comply with
the information reporting requirements.
The Section 6056
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.
This Newsletter is protected by copyright. Material
appearing herein may be reproduced with appropriate credit.
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