Section 6056 Reporting

[Chaz]

Employer has employees spread out all over the country. Many of these employees are unionized and participate in various multiemployer welfare plans depending on their locations.

Employer is concerned about the Section 6056 reporting requirements for 2015 (i.e., providing information whether it offers its full-time employees with affordable, minimum value coverage). It does not have information about the employee contribution for coverage under the multiemployer arrangements (it generally only knows its contribution to the funds). Employer is particularly concerned that the funds may not be willing to share this information with the employer.

The final section 6056 regulations provide that multiemployer funds are "permitted" to submit 6056 forms with respect to the full-time employees that participate in the funds but also that the employer is ultimately responsible for the filing. The IRS declined to require multiemployer funds to submit the form or even to provide information to employers with respect to information that it has in its possession.

Do you see multiemployers funds being willing to cooperate with employers in providing information so that employers will be able to satisfy their section 6056 obligations? Do employers have any recourse to obtain this information?

Thanks for any help you can provide.

[DTK_NJ]

Multiemployer plans routinely provide all sorts of information to contributing employers upon request. I don't see why this would be any different, especially given that the employer trustees administering those plans are going to be asking for the same information. I think it's fair to expect the plan to report on the employee premium requirements for the lowest cost plan that meets minimum value. It's probably wishful thinking to expect the multiemployer plan to do the filing itself on behalf of each contributing employer.