Health Care Guidance Part Three
New Guidance Issued on
Health Care Reform
Form W-2 Reporting and
Group Health Plan Coverage
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
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 at:
The compliance chart can be found at:
If you have any questions about health care reform and how it impacts your business, please contact Ed Hammond at
; Stephanie Hicks at (248) 988-5893,
; or one of Clark Hill’s attorneys in the Labor and Employment Practice Group.