Benefit plan managers are coming back to some of the same old nagging problems as they set about trying to comply with Patient Protection and Affordable Care Act (PPACA) requirements.

“Applicable large employers” (ALEs) are supposed to send 1095-C forms describing their employees’ coverage to the employees, and to the Internal Revenue Service (IRS), in early 2016.

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PPACA Section 4980H requires ALEs to offer full-time employees affordable coverage with a minimum value or else face the risk of having to pay penalties.

In some cases, employers can document that they offer adequate coverage by simply checking a box on the 1095-C. Federal agencies have created a safe harbor rule employers can use to decide whether they can just check the box or must provide more documentation.

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The IRS and other agencies have been rushing to get the batches of interpretations that advisors need to use the Section 4980H safe harbor and other PPACA forms, procedures and interpretations out the door, but Erin Sweeney, a benefits lawyer at Miller & Chevalier, said in an interview that she is still running into areas of confusion.

One example is the long-running debate about what employers with unionized employees should do about multiemployer coverage.

In some cases, unions for actors, musicians, video editors and other workers who move from gig to gig organize the multiemployer arrangements to ensure that union members can keep the same coverage throughout the year. Rather than providing health coverage directly, the employer that employs the union members sends cash to the multiemployer plan.

In practice, the multiemployer plans have refused to fill out the 1095-C forms or give employers the information they would need to fill out the forms, Sweeney said.

Some multiemployer plan administrators have argued that providing the 1095-C information could violate the enrollees’ Health Insurance Portability and Accountability Act (HIPAA) health privacy rights, Sweeney said.

Some benefits tax advisors say the employers contributing to the multiemployer plans can simply check the box stating that they provide adequate coverage; others say those employers should describe the coverage they offer in more detail.

Sweeney, who has been involved with benefits law since 1989, said the uncertainty about the matter is an example of how PPACA implementation has been much more complicated than implementation of the other big benefits laws that have come out in recent decades.

“It’s a much bigger undertaking,” Sweeney said.

The IRS is an arm of the U.S. Treasury Department. The Treasury Department, the U.S. Department of Health and Human Services (HHS) and the U.S. Labor Department last held a tri-agency meeting with benefits lawyers at the American Bar Association (ABA) in 2014, Sweeney said.

One way for the departments to clear up some of the remaining confusion about PPACA compliance could be for them to participate in another tri-agency meeting with benefits professionals, Sweeney said.

See also: 3 ways PPACA 1095-C reporting may zap your clients