Today, the IRS released Notice 2010-62, which provides that employers will not be required to report the cost of group health plan coverage on Form W-2 issued for 2011. Employers will welcome this notice, which will allow them additional time to modify their payroll systems and procedures to address this new health care reform reporting requirement.

The IRS expects to issue guidance about the new reporting requirement by the end of 2010. We hope such guidance will address how self-funded group health plans will need to calculate the cost of group health plan coverage to be reported on Form W-2 for 2012 and later years.

The IRS has also prepared a draft of the Form W-2 for 2011, which will allow employers to voluntarily provide information about the cost of health coverage by appropriately completing box 12.

If you have questions regarding the requirements for external claims review, please contact Brian M. Pinheiro, 215.864.8511 or

As the federal health care reform effort gained steam, Ballard Spahr attorneys formed an initiative to monitor and analyze legislative developments. With federal health care reform now a reality, our attorneys are assisting employers in understanding the relevant changes and planning for the future. For more information on the firm’s Health Care Reform Initiative, please click here.