Employer clients filing 250 or more W-2 forms are required to report to employees the total cost of their employer-sponsored group
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health plan coverage under the Patient Protection and Affordable Care Act. The W-2 reporting requirement begins with th
e 2012 W-2 forms furnished to employees in January 2013.
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At this time, employers filing fewer than 250 W-2 forms do not need to report cost of coverage on W-2 forms. This transition relief will continue until further guidance is issued.
Keep in mind that this requirement is informational only and does not mean that employer-sponsored coverage is subject to income tax.
Ultimately, it is the employer”s responsibility to accurately determine which employees should receive cost of coverage information. Your clients are encouraged to consult with their legal counsel or tax preparer for advice on what should be reported to meet the W-2 Reporting requirement.
Finding Cost of Coverage Data for Employees
Suggestions for your clients to find the data to calculate the cost of coverage include:
1. Review the 2012 bills from your carrier.
2. Talk to payroll vendor and request data for each employee.
3. Fully insured clients may log on to Employer eServices to view monthly invoices to find the premium costs per employee.
4. Self-funded clients should contact their COBRA vendor for a COBRA rate, if applicable.
What Not to Report
Health Insurance Portability and Accountability Act (HIPAA) “excepted benefits” plans (accident, disability income, supplemental liability, workers’ compensation insurance) are not subject to the W-2 reporting requirements.
Health flexible spending accounts (FSA) funded solely through employee salary reductions are not reportable. Employers are required to report the FSA value when it exceeds
the employee’s cafeteria plan election for all tax favored benefits. In addition, coverage under a health reimbursement account/arrangement (HRA) may be reported on the W-2 at the option of the employer.
W-2 Reporting Recap
The W-2 Reporting: IRS Recap of What to Report chart outlines what coverage should and should not be reported on the W-2 form.
For More Information visit the W-2 Reporting provision page on the IRS website.