What to Include or Exclude in ACA W-2 Reporting

Under the Affordable Care Act (ACA), employers are required to begin informational reporting to employees of amounts spent on certain health plan items. The IRS has provided guidance in the form of FAQs to assist employers in such reporting.

The Internal Revenue Service has published a chart (reproduced below) that details the type of coverage taken into account for Box 12, Code DD reporting.

Payroll systems—whether handled internally or provided by third-party vendors—will need to capture data from the employer that has historically not been part of a payroll system. Employers therefore should familiarize themselves with the specifics of the new requirements. Please note that the items reported must include both employer and employee contribution amounts.

Form W-2 Reporting of Employer-Sponsored Health Coverage

Coverage Type

Report

Do Not Report

Optional

Major medical plan.

X

Dental or vision plan not integrated into another medical or health plan.

X

Dental or vision plan which gives the choice of declining or electing and paying an additional premium.

X

Health flexible spending arrangement (FSA) funded solely by salary-reduction amounts.

X

Health FSA value for the plan year in excess of employee's cafeteria plan salary reductions for all qualified benefits.

X

Health reimbursement arrangement (HRA) contributions by employer.

X

Health savings account (HSA) contributions (employer or employee).

X

Archer medical savings account (Archer MSA) contributions (employer or employee).

X

Hospital indemnity or specified illness (insured or self-funded), paid on after-tax basis.

X

Hospital indemnity or specified illness (insured or self-funded), paid through salary reduction (pretax) or by employer.

X

Employee assistance plan (EAP) providing applicable employer-sponsored health care coverage.

Required if employer charges a COBRA premium

Optional if employer does not charge a COBRA premium

Onsite medical clinics providing applicable employer-sponsored health care coverage.

Required if employer charges a COBRA premium

Optional if employer does not charge a COBRA premium

Wellness programs providing applicable employer-sponsored health care coverage.

Required if employer charges a COBRA premium

Optional if employer does not charge a COBRA premium

X

Domestic partner coverage included in gross income.

X

Governmental plans providing coverage primarily for members of the military and their families.

X

Federally recognized Indian tribal government plans and plans of tribally charted corporations wholly owned by a federally recognized Indian tribal government.

X

Self-funded plans not subject to federal COBRA.

X

Accident or disability income.