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Health Care Guidance Part Three

May 29, 2014



, 2012

New Guidance Issued on

Health Care Reform

Form W-2 Reporting and

Group Health Plan Coverage


Stephanie Hicks

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:,,id=237894,00.html

The compliance chart can be found at:,,id=254321,00.html

If you have any questions about health care reform and how it impacts your business, please contact Ed Hammond at

(248) 988-1821,

; Stephanie Hicks at (248) 988-5893,

; or one of Clark Hill’s attorneys in the Labor and Employment Practice Group.

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