January 5, 2012
A new Notice (2012-9) has modified previous interim guidance on the Patient Protection and Affordable Care Act's (PPACA's) information reporting requirement for employer-sponsored health coverage. Like the previous guidance, the Notice provides guidance on the nuts and bolts of the information reporting rule for employers who will be subject to it, and those employers that choose to voluntarily comply with it.
In particular, Notice 2012-9 includes the following changes to Notice 2011-28:
-
revised Q&A 3 clarifies the application of the interim relief from the reporting requirement for employers filing fewer than 250 Forms W-2 for the preceding calendar year;
-
revised Q&A 7 clarifies the application of the reporting requirement to certain related employers not using a common paymaster;
-
Q&A 19 adds a new example that demonstrates that the reporting requirement doesn't apply to coverage under a health FSA if contributions occur only through employee salary reduction elections;
-
revised Q&A 20 clarifies that the standard for determining whether coverage under a dental plan or vision plan is subject to the reporting requirement is based upon the same standard for determining whether the coverage is subject to the rules set out in the regs under the Health Insurance Portability and Accountability Act of '96 (HIPAA)
Source: Federal Taxes Weekly Alert, January 5, 2012
Source: Federal Taxes Weekly Alert, January 5, 2012
This text is provided with the understanding that ECFA is not rendering legal, accounting, or other professional advice or service. Professional advice on specific issues should be sought from an accountant, lawyer, or other professional.