From what I’ve heard, the W-2 aggregate cost of benefits party organizers are rolling out the red carpet for medical this year. When they get to the door, they’ll be escorted right in and I’ve even heard their value is non-taxable. But I think some of the organizers may have forgotten about employee assistance programs. EAP invited to the W-2 party? Huh? Just as nobody puts baby in a corner (forgive the shameless reference to Dirty Dancing), nobody puts EAP in a corner!
First, take a look at question #32 in IRS Notice 2012-9 issued in January 2012 – http://www.irs.gov/irb/2012-04_IRB/ar10.html. Your initial reaction might be: “This doesn’t apply to me because I don’t offer our EAP benefit under COBRA so obviously don’t charge a premium for our EAP benefit under COBRA.”
