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Employers will be responsible for reporting to employees the total cost of their group health benefit plan coverage on their W-2 forms under the Patient Protection and Affordable Care Act. The reporting requirements are expected to apply to the 2012 W-2 forms which is information employers must report to employees in January 2013.

This requirement is informational only and does not mean that employer-provided coverage will become taxable. Employers filing fewer than 250 W-2 forms in 2011 will not be required to report the cost of coverage on any forms furnished to employees before January 2014.

Some benefits are not subject to the W-2 requirement:

  • HIPAA "excepted benefits" plans (accident, disability income, supplemental liability, workers' compensation insurance).
  • Stand-alone dental and vision plans.
  • Coverage under an HRA, amounts contributed to an HSA or an Archer MSA, as well as salary reduction contributions to a health FSA.
  • Coverage under a self-funded plan that is not subject to any federal continuation requirements (COBRA, PHSA continuation, FEHBP continuation), such as a group health benefit plan sponsored by a church. Coverage provided by the federal government, state government or agency of the government under a plan maintained primarily for members of the military and their families.
  • Coverage for a specific disease or illness or hospital indemnity insurance.

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