CBG Logo
Healthcare Reform Update




July 2012                                                                              Issue # 2012-4
Please take note of this important Healthcare Reform Update presented by Commonwealth Benefits Group. 

Gordon M. Graffius, CLU                          Bradley W. Graffius, CLU, RHU
CEO                                                            President

  • Must include the value of "employer-sponsored group health coverage" on W-2s beginning with the 2012 W-2 (to be issued in January 2013)
  • Except that, do not need to include this information if the employer issued fewer than 250 W-2s for the prior calendar year*
    • This means the number of W-2's issued in 2011 determines whether health care cost reporting is needed on the 2012 W-2s (issued in January 2013)
    • This exemption for smaller employers could change for 2014 and later years
    • Do not need to look at the whole controlled group when counting the number of W-2's issued
  • Reportable "group health coverage" includes:
    • Medical (PPO, HDHP, HMO, etc.)
    • Dental and vision if bundled with medical
    • Onsite medical clinics, EAP and wellness if a COBRA premium is charged
    • Hospital indemnity or specified illness if paid with pre-tax dollars
    • Employer-provided flex credits or flex dollars
  • Reportable "group health coverage" does not include:
    • Stand-alone dental and vision* (stand-alone means these benefits are elected separately from medical and have discrete premiums)
    • Life insurance
    • Short- and long-term disability and accident insurance
    • Long-term care
    • Employee salary reduction contributions to health FSAs
    • Hospital indemnity or specified illness paid with after-tax dollars
    • Onsite clinics, EAP and wellness, for which a separate COBRA premium is not charged*
    • Health reimbursement arrangements (HRAs)*
    • Health savings accounts (HSAs)
    • Multi-employer plans*
    • Workers' compensation
  • Must report the total cost of coverage (employer and employee contributions, whether paid pre-tax or after-tax) for all coverage provided to the employee and any covered family members
    • To determine cost, generally use the premium for insured benefits and the COBRA contribution (excluding the 2 percent administrative charge) for self-funded plans
    • If employee adds or discontinues coverage during year, must report based on periods (e.g. months) actually covered
    • If employee changes coverage level during year (e.g., from single to family), the reportable value is the sum of periods of single coverage and periods of family coverage
    • If premium increased or decreased during year, must reflect that in reported total cost
    • If employee terminates during year and elects COBRA, may report value of COBRA or not, as employer chooses (must report for all terminating employees the same way)
    • If any income is imputed (e.g., for domestic partners or dependent children over age 26), include that amount
  • Informational reporting only (i.e., reporting does not make benefit taxable)
  • Report in Box 12, using code DD
  • Do not need to issue a W-2 simply to report value of group medical (so reporting may not be needed for retirees or certain COBRA beneficiaries)
  • Do not include on W-3
  • Requirement applies to all types of employers -- private, government, church, not-for-profit
  • Requirement applies to grandfathered plans

Action Needed:

  • Determine if requirement applies - did employer issue more than 250 W-2s in 2011?
  • If requirement applies:
    • Verify can determine the value of health coverage provided to each employee during 2012
    • Verify payroll system/payroll vendor/W-2 provider is prepared to include this information on the W-2 beginning January 2013
    • Determine how the cost of coverage information will be provided to and accepted by the entity creating W-2s
    • Consider informing employees that this information will be reported on their W-2
      • Opportunity to remind employees of value of the coverage
      • Emphasize that reporting is informational, and does not mean employees are being taxed on the coverage
  • Timely issue W-2s with the required information in Box 12

Additional information is available at:

Compliance Alert 2012-01 - More IRS Guidance on W-2 Reporting of Health Coverage


IRS WEBSITE - Employer-Provided Health Coverage Informational Reporting Requirements: Questions and Answers


IRS WEBSITE - Form W-2 Informational Reporting of the Cost of Employer-Sponsored Group Health Plan Coverage

* - Employer may report this if it wishes to

About Our Office 
Commonwealth Benefits Group
2 Barlo Circle, Suite C
Dillsburg, Pennsylvania 17019
O:  717.432.1010
F:  717.432.2334

This notification is brought to you by your Member Firm of United Benefit Advisors - an alliance of more than140 premier independent benefit advisory firms and one of the nation's five largest employee benefits advisory organizations.