Health Care Cost Disclosure Update

Posted on Wednesday, September 19, 2012

In January 2012, the IRS issued Notice 2012-9 that provides additional clarification and guidance on Notice 2011-28 regarding employer-provided health coverage reporting requirements.  See our blog post, Health Care Cost Disclosure, posted August 31, 2011 for a summary of the health care cost disclosure requirements.

Notice 2012-9 provides transitional relief which will postpone the reporting requirements for some employers and types of plans.  All employers that provide “applicable employer-sponsored coverage” under a group health plan are subject to the reporting requirement except for the following employers and types of plans which receive transition relief under Notice 2012-9.  The following will not be required to disclose health care costs on their 2012 W-2 forms (W-2 forms required for calendar year 2012 issued in 2013) or future calendar years until the IRS publishes guidance giving at least six months of advance notice of any change to the transitional relief.  However, these employers and types of plans may voluntarily report costs.

  1. Employers filing fewer than 250 W-2 forms for the previous calendar year (W-2  forms required for 2011 issued in 2012)
  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 a choice of declining the coverage or electing it and paying an additional premium
  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
  7. Employers furnishing W-2 forms to employees who terminate before the end of a calendar year and request a W-2 form before the end of the year

If your organization provides applicable employer- sponsored coverage under a group health plan and does not fall into one of the seven categories above, you are required to report certain health care costs on your W-2 forms required for 2012 issued in 2013.

Posted by: Carrie Minnich, CPA

Posted in Mission Minded Nonprofits

Disclaimer: The information contained in Dulin, Ward & DeWald’s blog is provided for general educational purposes only and should not be construed as financial or legal advice on any subject matter. Before taking any action based on this information, we strongly encourage you to consult competent legal, accounting or other professional advice about your specific situation. Questions on blog posts may be submitted to your DWD representative.

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