Under Healthcare Reform, the IRS is changing some requirements that employers must comply with regarding how the cost of employer-sponsored health coverage is reported on W-2 forms provided to employees. Long story short, employers do not have to report the cost of employer-sponsored health coverage on form W-2 until 2013 for the 2012 calendar year.
On January 3, 2012, the IRS released Notice 2012-9 which restates and clarifies its prior guidance on the requirement under the Affordable Care Act (Healthcare Reform) to report the cost of employer-sponsored health coverage on employees’ annual forms W-2 (using box 12, code DD). Notice 2012-9 supersedes the prior guidance issued under Notice 2011-28 and clarifies various aspects of the reporting requirement. The reporting requirement is effective starting with the 2012 forms W-2 for calendar year 2012 that employers are generally required to furnish to employees in January 2013.
The requirement applies to most employers, including federal, state and local
government entities, churches and other religious organizations, and employers that are not subject to continuation coverage requirements under COBRA, to the extent such employers provide applicable employer-sponsored coverage under a group health plan. Employers who only sponsor self-insured group health plan coverage that is not subject to COBRA are not required to report the cost of the coverage on Form W-2.
Notice 2012-9 clarifies that until further notice, the exemption for federally recognized Indian tribal governments is expanded to include employers that are tribally chartered corporations wholly owned by federally recognized Indian tribal governments.
This information is provided as guidance. Sterling HSA and Sterling SIA do not provide tax advice. For clarification and details, readers of this information should contact their tax advisor.




