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Banyan Administrators have been providing us with beneficial information about several different aspects of the Health Care Reform and how it affects us. Over the next months and years, employers will be faced with numerous changes, many of which require regulatory clarification. Banyan will continue to keep us up to date and on target with decisions that affect our plans.

The following information is from Banyan Administrators:

Health Care Reform W2 Reporting

What You Need to Know Now About: W-2 Reporting

On March 31, 2011, the Internal Revenue Service (IRS) released the 19-page Interim Final Rules on the Health Care Reform W-2 reporting requirements. The IRS is still taking comments on the rules for the next 60 days. 

1.       What needs to be reported on the W-2 form?

Employers must report the costs for a group health plan. This does not include dental and vision plans unless the plans are integrated in the group health plan. Disability and long term care plans are also excluded from the reporting requirement.

2.       How do I determine the cost for the group health plan?

The cost includes both the employee contribution and employer contribution. Employers with fully-insured health plans should use the monthly premium rate. Employers with self-funded health plans should use the COBRA premium equivalent rates less the 2% administrative fee. Employer contributions into Medical Savings Accounts (MSA), Health Savings Accounts (HSA), Health Reimbursement Accounts (HRA) and, in most instances, Flexible Spending Accounts (FSA) are excluded.

3.       Where do I enter this information on the W-2 Form?

The information is entered in Box 12 on the W-2 form using code DD.

4.       Will the amount be included as taxable income for my employee?

No it will not. The first page, first bullet of the IRS Interim Final Rules state, “This reporting to employees is for their information only, to inform them of the cost of their health care coverage, and does not cause excludable employer-provided health care coverage to become taxable.”

5.       When do I have to be ready to comply with the new W-2 reporting requirement?

If you issue more than 250 W-2 forms for tax year 2011, you are required to comply with the new requirement for the 2012 tax year W-2 forms that are distributed to employees in January, 2013. You do have the option to comply earlier, if desired. However, remember that a terminating employee in calendar year 2012 can ask for an early W-2 so, in reality, you will need to be ready to comply as early as January, 2012.

Employers that issue 250 or fewer W-2 forms for tax year 2011 can receive “transition relief” from this requirement until January, 2014.

If you have any questions on this health care reform provision, please discuss with a member of your Banyan Consulting team.

[Information Source]

Banyan Administrators have been providing us with beneficial information about different aspects of the Health Care Reform and how it affects us. Over the next months and years, employers will be faced with numerous changes, many of which require regulatory clarification. Banyan will continue to keep us up to date and on target with decisions that affect our plans. 

To view this article in PDF format, click here.

The following information is provided by Banyan Administrators:

Another component of the Health Care Reform Act signed into law on 3/23/2010 is that beginning with the 2011 tax year, employers must report the aggregate cost of applicable employer-sponsored health insurance coverage on employees W-2 forms.  General information about this requirement has been provided, however, the Department of Labor (DOL) has not yet issued Interim Final Rules on this provision of the Health Care Reform Act.

1. When does an employer have to be ready to be in compliance with this new reporting requirement?

Employers must be prepared to accurately report this information on an employee’s 2011 W-2 form as early as February, 2011.  Although employers will be sending most of the 2011 W-2 forms to the employees in January, 2012, if an employee terminates employment in 2011, they do have the right to request an early 2011 W-2 form.  Employers must be prepared for this possibility. (continue reading…)