Michael Lloyd Quoted in Bloomberg BNA Regarding Expansion of TIN Matching Program

"Health Insurers Ask IRS to Expand TIN Matching Program for ACA Reporting"
Bloomberg BNA
11.19.13Michael Lloyd was quoted regarding the proposed expansion of the taxpayer identification number (TIN) matching program for reporting under the Affordable Care Act (ACA). Under proposed rules, insurers and self-insured employers may face penalties for incorrect or incomplete Section 6055 reports, including TIN information. According to Lloyd, who was testifying on behalf of the Blue Cross and Blue Shield Association (BCBSA) at a November 19 Internal Revenue Service (IRS) hearing, not allowing insurers to use the TIN matching program can result in confusion for taxpayers, information filers and the government. "Health insurers are some of the most compliant filers of information returns," Lloyd said. "Use of this program almost always results in lower name/TIN error rates."

While the IRS remains reticent to expand the program due to the potential of disclosing private taxpayer information, Lloyd said allowing insurers to request TIN information from employers, as opposed to taxpayers directly, could be a solution for complying with filing requirements. Clearly defining these requirements could keep a large number Americans from receiving penalty notices due to unclear information solicitation rules. "I don’t think it's prudent for the IRS to be ambivalent about these rules," Lloyd said. "It is a very specific area of law, and you have to really think about the insurance or health coverage application, enrollment and renewal process in order to kind of get to the right answer on how the TIN solicitation rules should be applied. I'm just not sure whether the Service has really done that yet." This article was also published in the BNA Snapshot on November 19, 2013.
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