Clerk of the House of Representatives
Legislative Resource Center
135 Cannon Building
Washington, DC 20515
http://lobbyingdisclosure.house.gov 		Secretary of the Senate
Office of Public Records
232 Hart Building
Washington, DC 20510
http://www.senate.gov/lobby
LOBBYING REPORT

Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page

1. Registrant Name Organization/Lobbying Firm Self Employed Individual
National Association of Professional Employer Organizations

2. Address

Address1
707 North St. Asaph Street
 Address2
​
City
Alexandria
 State
VA
 Zip Code
22314
 Country
USA

3. Principal place of business (if different than line 2)

City
​
State
​
Zip Code
​
Country
​
4a. Contact Name b. Telephone Number c. E-mail
​Mr.
​Thomas Stohler
​7037398167
​tstohler@napeo.org
5. Senate ID#
​400399882-12
7. Client Name Self Check if client is a state or local government or instrumentality
​National Association of Professional Employer Organizations
6. House ID#
​405810000
TYPE OF REPORT 8. Year
​2025
 Q1 (1/1 - 3/31) Q2 (4/1 - 6/30) Q3 (7/1 - 9/30) Q4 (10/1 - 12/31)

9. Check if this filing amends a previously filed version of this report

10. Check if this is a Termination Report Termination Date
​
11. No Lobbying Issue Activity
INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13
12. Lobbying 13. Organizations
INCOME relating to lobbying activities for this reporting period was: EXPENSE relating to lobbying activities for this reporting period were:
Less than $5,000
Less than $5,000
$5,000 or more $
​
$5,000 or more $
​180,000.00
Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options.
Method A. Reporting amounts using LDA definitions only

Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code

Method C. Reporting amounts under section 162(e) of the Internal Revenue Code

Signature
Digitally Signed By: Thomas Stohler
 Date
7/24/2025 3:58:45 PM

LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.

15. General issue area code TAX

16. Specific lobbying issues

HR 3223 - To amend the Internal Revenue Code of 1986 to establish procedures relating to the attribution of errors in the case of third party payors of payroll taxes, and for other purposes - NAPEO is lobbying in support of this legislation. H.R. 3223 would ensure that payroll tax credit claims filed on an aggregate return by third-party payors are not delayed due to problems with any one clients claim, and that the liability for any improper claims is assigned to the entity that initiates and benefits from the claim unless the third-party payor failed to take certain clear steps prior to filing the claim. By taking these actions, the federal government would save money by clarifying responsibility for payroll tax credits and deterring fraud and small businesses would receive their payroll tax credits in a more timely manner.

Specifically, this legislation would:

Ensure that any IRS audit or examination of a small business client of an aggregate tax filer does not delay the processing of any payroll tax credits claimed by the PEO or other third-party payor on behalf of other small business clients.

Confirm that, with respect to any employer payroll tax credit, the small business client benefiting from the payroll tax credit is liable, and the PEO or other third-party payor is not liable, for any improperly claimed credit amount, provided that the PEO or other third-party payor took certain clear steps including:

oVerifying certain wage information of which the PEO or other third-party payor has direct knowledge and collecting a certification from the client that includes certain information.

oAccurately reporting the credit in accordance with the information certified by the client.

oProviding the IRS with any information in its possession that the IRS could require the employer to provide, if needed to audit the employer.

Be business-model neutral with respect to entities that file aggregate employment tax returns, that is, available to PEOs, IRS-certified PEOs, and agents under Code section 3504.

IRS Modernization: NAPEO is lobbying Congress to call attention to the need for the IRS to use modern technology to process our tax claims. Specifically, we are asking Congress to require the IRS to use electronic returns and allow for transparency in the processing of tax returns submitted by PEOs.

Additionally, NAPEO continues to work with Congress and the IRS to process amended tax returns containing Employee Retention Tax Credits (ERTC).

17. House(s) of Congress and Federal agencies Check if None

Treasury - Dept of, U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS)

18. Name of each individual who acted as a lobbyist in this issue area

First Name Last Name Suffix Covered Official Position (if applicable) New
Thomas`
Stohler
​
Acting Assistant and Deputy Assistant Secretary, Occupational Safety and Health Administration, U.S. Department of Labor
Thomas
Stohler
​
Senior Legislative Officer, Office of Congressional and Intergovernmental Affaris, U.S. Department of Labor
Thomas
Stohler
​
Legislative Director, Rep. John Boehner
Alex
Milliken
​
​

19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None

​

Information Update Page - Complete ONLY where registration information has changed.

20. Client new address

Address
​
City
​
State
​
Zip Code
​
Country
​

21. Client new principal place of business (if different than line 20)

City
​
State
​
Zip Code
​
Country
​

22. New General description of client’s business or activities

​

LOBBYIST UPDATE

23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client

First Name
Last Name
Suffix
First Name
Last Name
Suffix
1
​
​
​
3
​
​
​
2
​
​
​
4
​
​
​

ISSUE UPDATE

24. General lobbying issue that no longer pertains

​
​
​
​
​
​
​
​
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AFFILIATED ORGANIZATIONS

25. Add the following affiliated organization(s)

Internet Address:

Name Address Principal Place of Business
(city and state or country)
Street Address
City State/Province Zip Country
City
State Country

26. Name of each previously reported organization that is no longer affiliated with the registrant or client

1 2 3

FOREIGN ENTITIES

27. Add the following foreign entities:

Name Address Principal place of business
(city and state or country) 		Amount of contribution for lobbying activities Ownership percentage in client
Street Address
City State/Province Country
City
State Country
%

28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization

1 3 5
2 4 6

CONVICTIONS DISCLOSURE

29. Have any of the lobbyists listed on this report been convicted in a Federal or State Court of an offense involving bribery, extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering?

Lobbyist Name Description of Offense(s)