IRS issues guidance on W-2 reporting

On January 3, 2012, the IRS issued additional interim guidance on the W-2 reporting requirement that is part of health care reform. In this guidance, the IRS confirms that employers filing fewer than 250 W-2s are not required to report the value of health benefits. This guidance extends that relief until further guidance is issued.

Additionally, the release indicates that specialty coverage, if included with medical benefits, must be reported.

The guidance reaffirms that this is a reporting requirement only and does not impact employees’ taxable wages.

Questions and Answers:

Q:   Are specialty products, if offered as one plan to an employee, included in the W-2 reporting requirement?

A:    According to the latest guidance from the IRS, yes. If the products are embedded or provided together, the total must be reported.

Q:   How do contingent premium groups report the value of health benefits under the W-2 reporting requirement?

A:    Please refer any customers with this question to their own tax and/or legal advisers as we do not provide tax advice. The latest information from the IRS related to the W-2 reporting requirement can be found at and may provide additional guidance.

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