Patient Protection and Affordable Care Act (PPACA), W-2 Reporting Requirements

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  • November 16, 2012

Government Service Administrators (GSA) is taking a proactive approach in assisting our clients in achieving compliance with the Patient Protection and Affordable Care Act (PPACA) requirements for 2012 Forms W-2 Reporting.

The PPACA requires employers to report the total cost of all applicable employer-sponsored group health plan coverage, starting with the 2012 calendar year. This information must be reported to employees on their 2012 Forms W-2 issued in January 2013.

In preparation for the January 2013 reporting requirements, GSA is providing the following matrix for your review and individual assessment of your business. The requirements vary, according to the type of business, health coverage and employee. The matrix is intended to provide guidance for reporting requirements, and is not to be used as a definitive benchmark for meeting your obligations under the law.

Questions? We’re always just a phone call away.

If you have questions about this new cost of coverage reporting requirement or any other healthcare reform provision, feel free to contact us at 1-800-250-2741, ext. 170 or via email at Solutions@gsanational.com.

Transition Relief Report on
Form W-2
Do Not Report on Form W-2 Optional Reporting
Small Employers** Employers required to file fewer than 250 Forms W-2 for the 2011 calendar year XNote:  Total employees include SCA and Non-SCA
Employees terminatingprior to the end of the calendar year, requesting a Form W-2 before the end of that year XNote:  Requirement is to report on health coverage when the Form W-2 is issued in January of the following year
Multi Employer Plans X   
Health Reimbursement Arrangements   X   
Dental and Vision Plans not integrated into another group health plan   X   
Self-Insured Plans of employers not subject to COBRA continuation coverage or similar requirements   X   
Coverage Type Report on Form W-2 Do Not Report on Form W-2 Optional Reporting
Dental and Vision Planswhich provide the choice of declining or electing and paying and an additional premium     X 
Health FSA Value for the plan year in excess of employee’s cafeteria plan salary reductions for all qualified benefits X     
Employee Assistance Plan (EAP) providing applicable employer-sponsored healthcare coverage XNote:  Required if employer charges a COBRA premium   XNote:  Optional if employer does not charge a COBRA premium
Self-Funded Plans not eligible for COBRA     X
Multi-Employer Plans     X
Domestic Partnercoverage included in gross income X    
Wellness programsproviding applicable employer-sponsored healthcare coverage XNote:  Required if employer charges a COBRA premium   XNote:  Optional if employer does not charge a COBRA premium
Coverage Type Report on Form W-2 Do Not Report on Form W-2 Optional Reporting
On-site medical clinicsproviding applicable employer-sponsored healthcare coverage XNote:  Required if employer charges a COBRA premium   XNote:  Optional if employer does not charge a COBRA premium
Exclusions Report on Form W-2 Do Not Report on Form W-2 Optional Reporting
Coverage for Long Term Care   X   
Archer Medical Savings Account (Archer MSA) contributions   X   
HIPAA Excepted Benefits   X  
Hospital Indemnity orspecified illness(insured or self-funded) paid through salary reduction (pre-tax) or by employer   X  
Health Flexible Spending Arrangement(FSA) funded solely by salary-reduction amounts   X  
Military Plan provided by a government entity   X  
Federally recognizedIndian tribal government plans and plans of tribally charted corporations wholly owned by a federally recognized Indian tribal government   X  
Health Savings Arrangement (HSA) contributions (employer or employee)   X   
Accident or Disability income   X  
Long Term Care   X  
Liability Insurance   X  
Supplemental Liability Insurance   X  
Workers’ Compensation   X  
Automobile medical payment insurance   X  
Credit-only insurance   X  
Excess reimbursementto highly compensatedindividual   X  
Payment/reimbursement of health insurance premiums for 2% shareholder-employee, included in gross income   X  
Situations Report on Form W-2 Do Not Report on Form W-2 Optional Reporting
Multistate employee XNote:  Determine the requirements of both the resident and the working state   X 
Forms W-2 provided by third-party sick-pay provider to employees ofother employers   X
Independent Contractors XNote:  If re-classified as employees  

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