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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 13, 2014


 State and Federal Law Alert




Final 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").


PPACA added 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 tax credit.


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 advertising.