Health Care Act W-2 Requirements: To Report or Not To ReportThat is the Question
By Stephen H. Harris, Eric Keller & MAlyssa Mecenas
The Patient Protection and Affordable Care Act amended the Internal Revenue Code (Code) to generally mandate that employers report on Form W-2 the aggregate cost of employer-sponsored health care coverage (the cost of coverage that is non-taxable under Code Section 106 or would be non-taxable if provided by an employer) for most types of plans with respect to 2012 and beyond. The stated purpose of this reporting requirement is to provide employees with information on the value of employer-provided healthcare. Recently issued interim IRS guidance (Notice 2011-28) clarifies the reporting requirements.