Healthcare reform and the 2012 W-2

The Affordable Care Act could have a blog all unto itself. For employers it will be like ribbon being unfurled from a high rise window, it will be rolling out for the next few years. Today we'll look at an immediate change and clear some confusion.

One of the questions that has come up quite a bit as we approach the end of the year revolves around the W-2. Business owners are still confused about their obligation to report health care contributions on the employee W-2. For most employers it is simple this year; you get a pass!

Here is how it works:

For the 2012 W-2 which must be post marked by January 31st 2013 contributions made by the employer toward employee health benefits in a company sponsored plan must be reported on the W-2.

Not all employers are required to do this for 2012.  Only the big guys, employers who issued 250 or more W-2 form in 2011 will have to include the additional information in 2012. There are other circumstances that relieve the employer from this requirement for 2012. The fewer than 250 W-2 forms threshold will cover most small businesses this year. Here is a list of the other relieves.

(2) multi-employer plans;

(3) Health Reimbursement Arrangements;

(4) dental and vision plans that either

• are not integrated into another group health plan or
• give participants the choice of declining the coverage or electing it and paying an additional premium (see Q&A-20 of Notice 2012-9 for more information);

(5) self-insured plans of employers not subject to COBRA continuation coverage or similar requirements;

(6) employee assistance programs, on-site medical clinics, or wellness programs for which the employer does not charge a premium under COBRA continuation coverage or similar requirements; and

(7) employers furnishing Forms W-2 to employees who terminate before the end of a calendar year and request a Form W-2 before the end of that year.

For more detail here is a link to the IRS website. Reach out to me directly if you would like professional human interaction on this and other HR topics.