Comptrollers Seek Extension of Health Coverage Reporting Relief 

October 21, 2020

Internal Revenue Service
Room 5203 P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20044

Attn: CC:PA:LPD:PR (Notice 2020-76)
Transition Relief Related to Health Coverage Reporting Required by I.R.C. Sections 6055 and 6056 for 2020

Dear Sir/Madam:

On behalf of the National Association of State Comptroller's Payroll Information Sharing Group, we thank you for the opportunity to provide our views on Notice 2020-76: Transition Relief Related to Health Coverage Reporting Required by I.R.C. Sections 6055 and 6056 for 2020. We very much appreciate the Internal Revenue Service (IRS) issuing Notice 2020-76 to extend from January 31, 2021, to March 2, 2021 the due date for certain 2020 information reporting requirements under sections 6055 and 6056 addressing health insurance and information returns regarding coverage.

Notice 2020-76 requests comment on whether an extension of the due date for furnishing statements to individuals under section 6056 will be necessary for future years and if so, why. The IRS in its notice also indicates that it has received little comment on the extension. The National Association of State Comptrollers represents state comptroller offices from across the nation. Many of these offices include the payroll and information reporting function for hundreds of thousands of public employees nationwide.

This provision remains difficult to implement and we would again respectfully request that the IRS make permanent the extension of the due date to provide employees forms 1095-B and 1095-C for future years. Our previous comments to your office still hold true in that employers pay employees in arrears which means that work hours are not finalized for the previous year until January. Additionally, most offers of coverage are not finalized until mid-January. Due to information needed for filing not being available until mid to late January, issuance of accurate forms to employees by January 31^st is very challenging and leads to unavoidable corrections. A permanent extension would allow for more accurate forms by utilizing more finalized hours and offers of coverage including accounting for any retroactive offer of coverage changes that may occur in mid to late January.

As was noted in our previous correspondence, the IRS Advisory Council noted similar concerns in their annual public report for 2019 stating that “the human resource and benefit administration systems have frequent retroactive entries meaning that in the absence of an extension, the IRS may be inundated with requests for an extension or issuers will be unduly burdened by the need to issue revised or corrective forms.”

Providing a permanent extension of the due date for future years would reduce the need for numerous corrections, alleviate any unintentional errors and avoid an avalanche of individual extension requests.

Thank you for the opportunity to comment on the need for permanent extension in future years. Should you have any questions or desire any additional information, please feel free to reach out to our representative in Washington, Cornelia Chebinou, at (202) 624-5451 or cchebinou@nasact.org.

Sincerely,

Jeremy Pigott, Co-Chair
Payroll Information Sharing Group

Steve Nielson, Co-Chair
Payroll Information Sharing Group

National Association of State Auditors, Comptrollers and Treasurers
Lexington, KY