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We have a doctor client who shares employees with other doctors. The 6 doctors operate under different tax entities. One doctor pays all the employees through his payroll for convenience. Their accountant charges the other 5 doctors their share of wages. The accountant tracks hours worked for each physician and allocates compensation accordingly. Some employees work for all and some only for one doctor or several doctors. So at the end of the year we get a census showing hours/wages for each physician and a total. I understand the very old regulations for shared employees are still in place which say you look at the total hours for all employers in determining the 1000 hours threshold and then allocate the employer contribution only on the wages paid applicable to a particular physician's business. My concern of course is - would the IRS support their own regs in this case? The good thing is that only 1 of 6 physicians even has a plan so in looking at the group as a whole, coverage likely would pass. I believe the group has a common marketing name and phone number. I don't know how they bill insurance - I hope and fully expect that to be filed under each of their separate business EINS. Thoughts? And thank you in advance. Tom
