W-2 Reporting Requirements

Requires all employers (including government entities) to include the aggregate cost (whether paid by the employer or the employee) of employer-sponsored health benefits on the employees’ annual Form W-2. The specific value attributable to each benefit is not required.

If an employee receives health insurance coverage under multiple plans, the employer must disclose the aggregate value of all such health coverage.

The coverage costs that must be reported (whether under an insured or self-insured plan) include:

o Medical plans
o Prescription drug plans
o Dental and Vision plans (unless they are each stand-alone plans)
o Executive physicals
o On-site clinics if they provide more than “de minimis” care (example: an on-site nurse who provides only emergency services)
o Medicare supplemental policies
o Employee assistance programs

Not required to be reported:
 
o Long-term care, accident, or disability income benefits
o Specific disease or illness policies, and hospital or other indemnity insurance policies where the full premium is paid by the employee on an after-tax basis
o All contributions to HSAs of the employee or employee’s spouse
o All contributions to Archer MSAs of the employee or the employee’s spouse
o Salary reduction contributions to FSAs as defined in IRC § 125

How Plan Value Is Determined:
 
o Use the same calculation as is currently used in determining the employer-provided portion of the applicable premiums for the taxable year for the employee determined under the rules for COBRA continuation coverage, including the special rule for self-insured plans.

Information must be available no later than February 1, 2011 (delayed until February 1, 2012 or 2013 – see note on right), in the event a terminating employee requests a W-2.

IMPORTANTBenefits payable during taxable years beginning on or after January 1, 2011.   Delayed until benefits payable during taxable years: beginning on or after January 1, 2012 for employers that issue 250 or more W-2s; beginning on or after January 1, 2013 for employers that issue fewer than 250 W-2s.

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