AGC Requests Clarification from IRS on Multiemployer Health Plans

On June 9, AGC submitted a letter to the Internal Revenue Service asking for clarification on the reporting process for employers that contribute to multiemployer health plans and the requirements to provide detailed information on the health care coverage employers’ offer.  Employers participating in multiemployer health plans are subject to additional complexity while trying to comply because many decisions and requirements are bound by the employer’s collective bargaining agreements.  Under the multiemployer plan model, a plan administrator has access to the information required by the IRS and reports this information, despite the reporting obligation remaining with the employer.

Previous guidance from the IRS has recognized the unique nature of these plans but the IRS has been inconsistent on the requirements for these employers. The rules issued by the agency and the actual instructions on the form employers must complete differ and are ambiguous. AGC and similar stakeholders are asking the IRS to change the reporting form and eliminate the ambiguity between the reporting forms and its guidance in the regulation.