IRS Issues Additional Guidance on PPACA Form W-2 Health Coverage Reporting

On January 23, 2012, the IRS issued Notice 2012-9, which provides additional guidance on the Patient Protection and Affordable Care Act (“PPACA”) requirement that employers report the aggregate cost of employer-sponsored health coverage on Form W-2 beginning with the 2012 Form W-2.  The guidance clarifies that an employer that contributes to a multiemployer plan or a health reimbursement arrangement (“HRA”) is not required to report the cost of such coverage.  The guidance also clarifies that the cost of stand-alone dental and vision coverage does not have to be reported, nor does the cost of coverage under an employee assistance program (“EAP”), wellness program or on-site medical clinic if the employer does not charge a COBRA premium with respect to such coverage.  The guidance also reiterates that employers that are required to file fewer than 250 Forms W-2 are exempt from the reporting requirement.