The mandate to report the cost of employer-sponsored group health plan coverage has been revised by IRS Notice 2012-9, issued just this week.
As many will recall, last summer the agency solicited public comment on various aspects of this requirement. This week’s revisions are in direct response to that feedback, and makes changes that may be of interest to TASC Providers/Clients regarding the following:
- A reprieve from the reporting requirement for employers who file fewer than 250 W-2s for the preceding calendar year.
- The cost of coverage included/excluded in the aggregate reportable cost (HINT: HRAs appear to be OUT, at least for the time being).
Beginning with 2012 W-2s (those reported by the end of January 2013), this “interim” guidance is applicable until further instructions are issued. Any future guidance will apply prospectively only and will not apply to any calendar year starting within six months of the release date.
The call-outs above are only two of 40 provisions addressed in this most recent notice. Rest assured that TASC Governmental Affairs staff is currently analyzing the entire document and will report further, as pertinent.