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IRS Puts COBRA Under Scrutiny: Consider a Self Audit or Pay the Price

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Jeremy Sharp is a partner with the law firm Walter & Haverfield in Cleveland.

By Jeremy J. Sharp

Employers beware: The Internal Revenue Service recently issued new revised audit guidelines for IRS auditors who review group health plans for COBRA compliance in the aftermath of a 10-year task force study. And, this review could end up being costly for your company if an IRS auditor should come knocking on your door.

Industry commentators feel these revised guidelines likely will trigger an increased audit emphasis by the IRS in respect to COBRA compliance. Chances are, if audited, most employers will have some sort of COBRA failure, inadvertent or otherwise. And, even if a compliance failure is unintentional, you still risk incurring stiff penalties.

For example, Section 4980B of the Internal Revenue Code imposes an excise tax for failure to comply with COBRA continuation coverage obligations and requirements. The $100 excise tax is assessed for each qualified beneficiary for whom the failure occurs, with a maximum of $200 per family. (more…)


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