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NAM Supports Relief From Health Coverage Reporting

FEB. 2, 2021

NAM Supports Relief From Health Coverage Reporting

DATED FEB. 2, 2021
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February 2, 2021

Internal Revenue Service
Attn: CC: PA: LPD: PR (Notice 2020-76) Room 5203
P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20044

Re: Notice 2020-76 Transition Relief Related to Health Coverage Reporting Required by Sections 6055 and 6056 for 2020

On behalf of the more than 14,000 members of the National Association of Manufacturers, the largest manufacturing association in the United States, the NAM submits these comments to the Internal Revenue Service in favor of long-term reporting relief for 2020 and future years as the ongoing extensions have provided the necessary time to ensure reporting accuracy under the obligations outlined under 6055 and 6056 of the Internal Revenue Code.

The NAM is the largest manufacturing association in the United States, representing manufacturers in every industrial sector and in all 50 states. The NAM is the powerful voice of the manufacturing community and the leading advocate for a policy agenda that helps manufacturers compete in the global economy and create jobs across the United States. Approximately 98 percent of NAM member companies offer health benefits to maintain a healthy workforce, attract and retain talent, and because they believe it is the right thing to do for their employees.

Extending the January 31 reporting deadline to March 2 does not change manufacturers' commitment to providing quality health coverage but assures greater accuracy and eases the regulatory burden associated with ongoing reporting requirements as required by the ACA. Employers typically consolidate data from multiple benefits systems (payroll, timekeeping, COBRA and retiree-medical vendor systems, etc.) to produce Form 1095-C. Pay periods that end in December and reflect hours worked during that month also take time to be processed, reviewed and approved. The current unreliability of the U.S. postal service only adds to the need for continued extensions. Manufacturers will always meet their reporting obligations under the law and appreciate this request designed to ease regulatory burdens with reasonable and justifiable additional time.

Comments Submitted by:

Robyn M. Boerstling
Vice President, Infrastructure, Innovation and Human Resources Policy
National Association of Manufacturers
733 10th Street NW, Suite 700
Washington, DC 20001

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