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IRS Delays Mandatory Implementation of W-2 Reporting Requirement for Cost of Employer-Sponsored Health Coverage

    Client Alerts
  • October 15, 2010

This week the IRS released Notice 2010-69. Notice 2010-69 provides that employers will not be required to report the cost of employer-sponsored health coverage for employees on Forms W-2 issued for 2011 (which generally would be furnished to employees in 2012). 

The W-2 reporting requirement was introduced in the Patient Protection and Affordable Care Act, as amended, and mandated that employers report the aggregate cost of applicable employer-sponsored health coverage provided to an employee on the employee's Form W-2. Now, after the release of the Notice, employers will have an additional year to modify their payroll systems and procedures to comply with the new reporting requirement.

In addition, the IRS released a draft of the 2011 Form W-2. The draft Form W-2 allows employers to voluntarily report the cost of health coverage for 2011 if they choose to do so.