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New Guidance Issued on Health Care Reform: Form W-2 Reporting and Group Health Plan Coverage

April 20, 2012

By Stephanie Hicks, courtesy of Clark Hill PLC, an SBAM Approved Partner
PPACA requires that employers with at least 250 employees must report the cost of employer-sponsored health care on an employee’s W-2, beginning with W-2s issued for 2012 (issued in 2013). On Feb. 15, 2012, the IRS released a set of FAQs discussing the rules for reporting employer-provided group health plan coverage on and an employee’s W-2, along with a useful chart that sets out the reporting requirements applicable to different types of situations and coverage.  
The FAQs provide that, for 2012, the W-2 reporting requirement does not apply to:

  • Employers that filed fewer than 250 W-2s for 2011
  • Multi-employer plans
  • Health reimbursement arrangements
  • Dental or vision plans that are stand-alone (or provide an election to decline coverage or accept it and pay an additional premium)
  • Self-insured plans of employers that are not subject to COBRA or other similar continuation coverage
  • Employee assistance programs, on-site medical clinics or wellness programs for which the employer does not charge a premium for COBRA or other similar continuation coverage
  • Employers furnishing Form W-2 to employees who terminated before year end and request a Form W-2 before year end

The FAQs also provide a convenient compliance chart that summarizes the reporting obligation for different coverage types and different coverage situations.
The FAQs can be found here.
The compliance chart can be found here.

To read about Auto Enrollment Waiting Periods, click here.

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