"Some of the required information may be compiled by your payroll service. But your payroll service probably will not track the following: [1] The date when coverage (as opposed to premium payments) begins and ends; [2] Evidence of your offer of group health coverage to eligible employees; [3] Any employee waivers of coverage; [4] The out-of-pocket employee cost of the lowest cost employee-only coverage.... [It's] going to be an employer responsibility to come up with required historic data and undertake a 'good faith' effort to comply in order to avoid IRS fines for submitting incomplete or inaccurate data."

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