The following is a brief summary of provisions likely to impact clubs in 2013:
- Withholding of additional Medicare tax of .9% on wages or compensation of over $200,000. Clubs that pay employees such as the greens superintendent and or general manager in excess of this amount, should update their payroll system or be sure their payroll processor is ready to comply. The good news is that there is no employer match of this tax as there is with the regular Medicare tax.
- Reporting of aggregate cost of health insurance is required on 2012 W-2’s (to be filed in 2013) if the club filed over 250 W-2’s for 2011. Provision to comply should be made now to avoid the end of year rush if your club exceeds the 250 W-2 threshold.
In 2014 of course, the full weight of the law will impact applicable clubs with “shared responsibility provisions”, also known as the “employer mandate”. Many clubs will be subject to these provisions as they are designed to affect employers with 50 or more “full time equivalent” employees. A full time equivalent employee is one who averages 30 hours worked per week. In general, the “shared responsibility provisions” will penalize employers who do not provide insurance that meets government guidelines and is affordable. As an example of the affordability guideline is that the cost to the employee for self coverage should not exceed 9.5% of an employee’s household income (safe harbor amount is the determined by the employee’s W-2 income). As the technical provisions for implementation are still a work-in-progress, more announcements will be forthcoming. In the meantime, you should contact your insurance provider now and begin a thorough compliance review.
