Health Care Reform, Insurance and Employee Benefits

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Health Reimbursement Arrangements (HRAs) and Annual W-2 Reporting

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.



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Clarifying Health is a blog about health insurance, health benefits, and everything else related to how Americans pay for medical expenses.

If you have any tips or suggestions for this blog, send an email to blog@ZaneBenefits.com and let us know. We always appreciate feedback

We also run a company called Zane Benefits where we're doing everything we can to help America out of the current healthcare mess.

If you want to learn more about how Zane Benefits helps companies with their benefits, or you're interested in working with us, visit the Zane Benefits website.
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