Are you scrambling to do your W2s at the last minute? Not to put any more pressure on you, but if you have 250 or more employees and didn’t see the joint memo by Stuart C. Harris, Sarah L. Bhagwandin, and Richard J. Birmingham two weeks ago about how the IRS recently provided new interim guidance to help employers report health care coverage costs on Form W-2, then I just wanted to give you a heads up.

As part of Congress’s healthcare reform, the IRS now requires employers to report the cost of health care coverage provided to employees. Employers must report the aggregate cost of “applicable employer-sponsored coverage” on Form W-2, regardless of whether the employee or the employer pays for the coverage. The IRS issued previous guidance in Notice 2011-28, but the newly issued Notice 2012-28 clarifies employer’s reporting obligations and replaces the previous guidance.