The Internal Revenue Service (IRS) recently issued Notice 2011-28 that provides important transition guidance and relief on reporting the cost of employer provided heath care coverage on Form W-2. However, beginning with the 2012 Form W-2 (which are furnished to participants in January 2013), most employers will be required to report the cost of health care coverage to employees.

The Notice is summarized in the attached memo. This guidance shall apply until further guidance is issued, and any additional guidance shall be prospective in nature (with at least 6 month lead time for system changes).

Since the enactment of PPACA, we have been working closely with employers, payroll and health care providers to implement this reporting requirement. This is an important first step in providing guidance in this area, and the IRS has left the door open for additional relief following comments on this Notice. If you have questions or concerns with the new guidance, or are in need of additional relief, please contact any of the Health and Welfare team attorneys.


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