Note: None of this should be taken as legal or tax advice.
As part of the
Affordable Care Act (ACA), employers are required to report the cost of health benefits coverage under an employer-sponsored group health plan.
Last week,
the IRS issued a notice confirming that employers
are not required to include the cost of coverage under a
Health Reimbursement Arrangement (HRA) on employee W-2s. If the only coverage provided to an employee is an HRA, the employer is not required to report any amount on the Form W-2 for that employee.
According to
Notice 2012-9, the IRS is granting permanent relief to employers that sponsor HRAs:
"Q-18: Is the cost of coverage under a Health Reimbursement Arrangement (HRA) required to be included in the aggregate reportable cost reported on Form W-2?
A-18: No. An employer is not required to include the cost of coverage under an HRA in determining the aggregate reportable cost. If the only applicable employer-sponsored coverage provided to an employee is an HRA, the employer is not required to report any amount under §6051(a)(14) on the Form W-2 for that employee."
Click here to read the full notice.