Information Reporting by Applicable Large Employers; Proposed Rule (November 8, 2013)

Health Care

From the Church Alliance to the Internal Revenue Service commenting on how the proposed rule for information reporting by applicable large employers on health insurance coverage offered under employer-sponsored plans (Section 6056 Reporting) under the Patient Protection and Affordable Care Act (PPACA) should be applied carefully to church employers. Section 6056 Reporting should be applied to churches at the level of the local church (i.e., a local church, parish, mosque, temple, synagogue or other local place of worship) rather than at the level of the denomination (i.e., the national or highest level of a church in the case of a hierarchical church, or a convention or association of churches in the case of congregational churches) or the intermediate organization level of a denomination (e.g., regional organizations, such as conferences, presbyteries, synods, or dioceses).