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Relief for Employers Issuing Fewer than 250 W-2s

Many of our clients with group health insurance in Georgia and elsewhere have been concerned about the burdens placed on them by the Patient Protection and Affordable Care Act (PPACA). One of these new requirements is that the aggregate cost of applicable employer sponsored coverage be reported on Form W-2.

The Internal Revenue Service just issued additional interim guidance in the form of Notice 2011-28. This notice grants transitional relief for employers that in the previous calendar year issued fewer than 250 Form W-2s.

For these smaller employers, reporting is now required starting with W-2s for the 2013 tax year, which would be issued in 2014.

This relief will continue at least through the 2012 Forms W-2 which are required to be furnished to employees in January 2013. In other words, smaller employers that are required to file fewer than 250 2011 Forms W-2 will not be required to report the cost of health coverage on any forms required to be furnished to employees prior to January 2014.

Additionally, Notice 2011-28 provides more clarification on how employers can calculate the cost of coverage to meet this reporting requirement. Reference questions 24 – 27 and question 31 in the Notice 2011-28. The guidance reaffirms that this is a reporting requirement only and does not impact employees’ taxable wages.

As always, please give us a call if you need help understanding your responsibilities under PPACA.