News

W2 Reporting IRS Releases Notice 2012-09

On January 2, 2012, the IRS released Notice 2012-09 which updates and amends Notice 2011-28 regarding the reporting of employer-sponsored group health plan on the 2012 W-2 Forms as required by the Health Care Reform Act.  Notice 2012-09 does not change the reporting requirement for employers, but, does provide additional guidance and clarification on certain topics.  Some highlights of the new Notice includes: 

• Clarification of the interim relief reporting requirement for employers filing fewer than 250 Forms W-2.
• The cost of coverage for employee assistance programs (EAP), wellness programs, or on-site medical clinics do not have to be reported if the employer does not charge a premium with respect to that type of coverage provided under COBRA to a qualifying beneficiary.
• Employers may include the cost of coverage for benefit programs, such as Health Reimbursement Accounts, that are excluded from the reporting requirement and clarification on how to calculate the cost.
• Clarification on other unique situations such as if a pay period extends over the end of the tax year on December 31^st, if a composite rate is charges for active employees but not for COBRA qualified beneficiaries, if certain related employers are not using a common paymaster, etc.