The Affordable Care Act requires employers to report the cost of "applicable employer sponsored coverage" (as defined by the Internal Revenue Service) on W-2 Forms for their employees. This reporting was intended to begin with the 2011 tax year but Notice 2011-28 made the reporting optional for 2011 for all employers, and provided additional transitional relief for certain employers and certain types of coverage.
In January 2012, the IRS issued additional interim guidance, Notice 2012-9, which extended the transitional relief for certain smaller employers and certain types of coverage.
Employers who filed fewer than 250 W-2s for the previous calendar year will not be subject to the reporting requirement for the 2012 tax year. For employers in this category, reporting would remain optional until at least six months after the IRS publishes guidance of any change to this transitional relief. Employers that do not fall within this small employer exception are required to begin reporting for the 2012 tax year.
Notice 2012-9 also provides transitional relief for certain types of coverage, including multi-employer plans, HRAs, stand-alone dental or vision plans, and others, meaning that reporting for those types of coverage is not currently required.
Blue Cross Blue Shield of Massachusetts will not be providing data for the employers to file the W-2 form.
For more information, please visit the IRS.gov website
This information is provided for informational purposes only and does not constitute legal advice. Please consult your legal counsel regarding your specific situation.
Please note that this content is only intended to describe national health care reform requirements under the Patient Protection and Affordable Care Act (PPACA). It does not address Massachusetts law requirements or the potential impact of Massachusetts law on federal PPACA requirements.
For purposes of PPACA implementation, Blue Cross Blue Shield of Massachusetts assumes the plan year is the policy year, unless an account notifies us otherwise.