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ACA XML - do we include Retirees and Cobra

Hello,

In a recent post, Amy mentioned we should check with legal on whether the retirees (and perhaps cobra) should be included in the XML transmission. Does anyone have a legal opinion about this? If so, could you point us to the IRS documentation that backs the opinion up?

Thank you,

Maureen Murphy

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unknown

I wanted to correct my post from this morning....what I'm really asking is if we include the retiree and cobra in our BN255 counts

DEPM-608_Data_Integration_BDS_dEPM12.mp4

unknown

We did get a legal opinion and it was determined the BN255 employee counts seems to be intended to determine whether we are an ALE, and is a separate issue from whether we are required to file forms on behalf of retirees and COBRA enrollees. Therefore we will be using the Lawson generated BN255 counts.

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