Employment, Labor & Benefits Advisory: IRS Issues Additional Guidance under the Affordable Care Act on Informational Reporting to Employees of the Cost of Group Health Insurance Coverage
2/3/2012
The Patient Protection and Affordable Care Act of 2010 requires employers that sponsor group health coverage to report to employees the aggregate cost of such coverage annually on their Form W-2 (Wage and Tax Statement). The W-2 reporting requirement appears in newly added Internal Revenue Code § 6051(a)(14), which was originally slated to take effect in 2011. But IRS Notice 2010-69 provided that W-2 reporting would not be mandatory until issuance of the 2012 W-2s.
In Notice 2011-28, the IRS furnished initial guidance under the Act’s W-2 reporting requirement. Recently issued Notice 2012-9, which restates and expands on Notice 2011-28, provides employers and plan sponsors with some additional and important clarifications.
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