IRS Issues New Guidance on W-2 Reporting of Health Plan Cost

March 9, 2012

The IRS recently issued new guidance (IRS Notice 2012-9) which requires certain employers to provide information to employees on the cost of employer-provided group health plan coverage. This additional reporting requirement was enacted as part of the Patient Protection and Affordable Care Act of 2010 (PPAC) to provide useful and comparable consumer information to employees on the cost of their health care coverage. Employers who file 250 or more W-2 Forms for the preceding calendar year are subject to this new requirement. Employers who are required to file will need to include monthly medical premiums for COBRA participants as part of the aggregate reportable cost. Dental and vision benefits that are excepted benefits for purposes of HIPAA are not required to be included, along with HSAs, most Health FSAs, HRAs and EAPs. Employer clients under contracted services of eCOBRA will be contacted by our eCOBRA Support Team later this year to assist you with the reporting under this new requirement.  We will release a new report to you before W-2s are generated for 2012 earned income. Listed below are several helpful links for more information about this IRS ruling. If you have any immediate questions, please contact our COBRA support team.

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