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P4ESC Comment Letter on IRS Notice 2020-76: Transition Relief Related to Health Coverage Reporting Required by Sections 6055 and 6056 for 2020 (PDF)
Partnership for Employer-Sponsored Coverage [P4ESC]Link to more items from this source
[Opinion]
Jan. 29, 2021

15 pages. "[The Partnership for Employer-Sponsored Coverage (P4ESC) strongly urges] the new Administration to: ... [1] Revise the list of data requirements under sections 6055 and 6056 to be relevant and practical ... [2] Decouple information reporting for sections 6055 and 6056 from Form 1095-C.... [3] Enable applicable large employers (ALEs) to prospectively report to the IRS relevant data items about the type of coverage offered to their workforce of full-time employees ... prior to open enrollment season in the Exchanges ... [4] Eliminate the requirement that self-insured employers send an individual 1095-C form to all enrolled employees.... [5] Require review of ALE-filed data before a 226-J penalty notification letter is sent.... [6] Provide employers with 90 days, rather than 30 days, to appeal a 226-J tax penalty letter for any tax compliance year.... [7] Work directly with HHS and state-based Exchanges to verify employer information during open enrollment to determine individual premium tax credit eligibility."

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