Reporting Employer Provided Health Insurance on Form W-2

The IRS has issued interim guidance on reporting the cost of employer-sponsored health insurance coverage on an employee's Form W-2 (IRS Notice 2011-28). Beginning with Forms W-2 issued for 2011, the Affordable Care Act requires employers to report the aggregate cost of employer-sponsored health care coverage on an employee's Form W-2. However, last fall, the IRS made the reporting requirement optional for all employers for 2011 Forms W-2. Notice 2011-28 provides further relief for smaller employers (those filing fewer than 250 Forms W-2) by making reporting optional for them for 2012 Forms W-2 and continuing this optional treatment for smaller employers until further guidance is issued. It also explains how to report the coverage on Form W-2, what coverage to include, and how to determine the cost of the coverage. While the guidance in Notice 2011-28 generally is applicable beginning with 2012 Forms W-2, employers may rely on it if they voluntarily choose to report the cost of coverage on 2011 Forms W-2.