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Health Care Reform Updates in 2015


IRS Issues Final Regulations on Health Plan Minimum Value and Affordability

The Internal Revenue Service (IRS) has issued final regulations on determining minimum value of eligible employer-sponsored plans and other rules regarding the health insurance premium tax credit.

The regulations contain an explanation of revisions and summary of comments on:

  • Definition of modified adjusted gross income
  • Wellness program incentives, including tobacco-related incentives
  • Employer contributions to Health Reimbursement Arrangements (HRA)
  • Employer contributions to cafeteria plans (flex contributions)
  • Post-employment coverage
  • Newborns, adopted children and other individuals enrolled midmonth
  • Partial months of coverage



Final Rules on Excepted Benefits Published

The US Departments of Labor, Treasury, and Health and Human Services have published the final rules amending the definition of excepted benefits under the Patient Protection and Affordable Act (ACA).

The four categories of excepted benefits are:

  1. Generally not health insurance such as automobile insurance, workers' compensation, and accidental death and dismemberment.
  2. Limited excepted benefits which may include limited scope dental or vision benefits and benefits for nursing home, home health, long-term, or community based care.
  3. "Noncoordinated benefits" which include coverage only for specified disease or illness (i.e., cancer policies) and hospital indemnity or other fixed indemnity insurance.
  4. Supplemental excepted benefits such as coverage supplemental to Medicare, CHAMPVA, Tricare, or similar coverage that is supplemental to group health plan coverage.

There are requirements for each category that must be met to qualify as excepted benefits. These are noted in the final rules which will be published in the Federal Register.



IRS Invites Public Comments on Future 'Cadillac Tax' Regulations

The Internal Revenue Service (IRS) Notice 2015-16 outlines potential approaches on a number of issues that could be included in the future proposed excise tax on high cost employer sponsored health coverage (also referred to as the "Cadillac tax"). In addition to inviting comments on these approaches, the Treasury Department and the IRS will issue another notice before the publication of the proposed regulations not addressed in this notice.