W-2 Reporting - Smoker Surcharge

[rocknrolls2]

I am looking into whether a health plan's smoker surcharge should be included in the cost required to be reported on the Form W-2. For the surcharge itself, since it is a type of wellness program, it seems clear that it would be reportable if coverage is provided under a group health plan. See IRS Notice 2012-9, Q&A-32. However, if the provider of the program charges the employer a program fee which is not passed through to employees, should that be included in the reportable cost since it is a cost of the group health plan? Or is it treated as a wellness program for which the employer does not charge a premium and would be excluded from the reportable cost?