Updated Guidance on Form W-2 Reporting of Healthcare Coverage

Morgan Lewis
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The Patient Protection and Affordable Care Act (Affordable Care Act) imposes on employers a new requirement to report the cost of employer-sponsored healthcare coverage. Notice 2012-9 (Notice), recently issued by the Internal Revenue Service, updates and expands prior guidance related to how employers must report such coverage. This LawFlash discusses the changes made to the reporting requirements under the Notice.

The Affordable Care Act generally requires annual reporting to employees of the “aggregate cost” of “applicable employer-sponsored coverage,” as defined below. Such coverage is reported on Form W 2, Wage and Tax Statement, and is first required for the 2012 calendar year (for which Forms W-2 must be distributed by the end of January 2013), although employers may voluntarily report such coverage for the 2011 calendar year.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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