Introduction
The Affordable Care Act (the “Act”) added reporting
requirements for large employers concerning health care insurance in section
6056 of the Internal Revenue Code. In addition, the Act also imposed
substantive standards for minimum essential coverage to be offered by large
employers, including cost standards.
Both the reporting requirements and the substantive
standards are enforced through penalties that are administered by the IRS.
Practitioners have been seeing these cases for a while now and some trends are
emerging that merit discussion.
My discussion of penalties under the Act will proceed in a
series of segments: In this part, I will review the reporting requirements and
the associated penalties; in a second part, I will review penalties under
section 4980H, which serve to enforce the Act’s requirements for minimum
essential coverage.… Read More