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Aon Hewitt Submits Comments on Reporting by Applicable Large Employers | Aon

Aon Hewitt Submits Comments on Reporting by Applicable Large Employers on Health Insurance Coverage Under Employer-Sponsored Plans

On June 11, 2012, Aon Hewitt submitted comments to the Internal Revenue Service (Notice 2012-33) in regards to reporting by applicable large employers on health insurance coverage under employer-sponsored plans, as added by the Patient Protection and Affordable Care Act (Affordable Care Act). The Notice, published on April 26, 2012, requests comments on Code Section 6056, which requires reporting for applicable large employers that are subject to the employer shared responsibility payment under Code Section 4980H.

In the comment letter, Aon Hewitt makes the following recommendations and asks the IRS to consider:

  • Reporting single Employer Identification Numbers (EIN) in certain situations;
  • Providing relief for non-calendar year plans;
  • Offering alternative reporting to determine plan affordability;
  • Allowing deductions for wellness credits; 
  • Allowing flexibility when determining full-time status and wages, consistent with other guidance; 
  • Offering a new safe harbor for reporting full-time employee status; and
  • Providing clarification of "employer's share."

Click here to read the full comment letter.