Reform Alert - News from the Blues' Office of National Health Reform

Further guidance on W-2 reporting requirements released on Jan. 3

Feb. 14, 2012

Note: This reform alert is an update of a previously published alert, W-2 reporting requirements expanded for some employers.

The Internal Revenue Service has issued additional guidance modifying previous requirements under the Affordable Care Act for informational reporting, asking employers to provide employees with their cost of employer sponsored health care on W-2 forms. 

This modified requirement applies to federal, state, and local governmental agencies, but it does not apply to federally recognized Indian tribal governments. Until further direction is provided, the W-2 reporting requirement will not apply to tribally chartered corporations owned by federally recognized Indian tribal governments. 

Employers are not required to include the cost of health coverage under an employee assistance program, wellness program, or on-site medical clinic if the employer does not charge a premium for COBRA coverage for a qualifying beneficiary. 

An employer can still voluntarily choose to include the coverage cost on W-2 forms for an employee assistance program, wellness program, on-site medical clinic, or the cost of coverage under a health reimbursement arrangement. 

If an employer reported on certain excepted benefits on a pre-tax basis under a cafeteria plan, which may include disease- or illness-specific coverage and indemnity insurance coverage, then the employer must include this in the W-2 reporting. 

Blue Cross Blue Shield of Michigan will continue to monitor activity on W-2 reporting requirements and provide updates as they become available. 

More information on W-2 reporting requirements (PDF) is on the Internal Revenue Service website.

The information on this website is based on BCBSM's review of the national health care reform legislation and is not intended to impart legal advice. Interpretations of the reform legislation vary, and efforts will be made to present and update accurate information. This overview is intended as an educational tool only and does not replace a more rigorous review of the law's applicability to individual circumstances and attendant legal counsel and should not be relied upon as legal or compliance advice. Analysis is ongoing and additional guidance is also anticipated from the Department of Health and Human Services. Additionally, some reform regulations may differ for particular members enrolled in certain programs such as the Federal Employee Program, and those members are encouraged to consult with their benefit administrators for specific details.