Affordability Safe Harbor The Un COLA

There have been a few articles and blog posts discussing the formula used to calculate affordability (and affordability safe harbors) under the Shared Responsibility provisions. HHS recently published regulations that apply a COLA adjustment to the current 9.5% threshold used for determining whether coverage is affordable from the individual’s perspective to qualify for a subsidy. The percentage will be 9.56% for 2015. However, this adjustment doesn't carry through to the employer affordability safe harbors — so the safe harbor options would still be 9.5% of FPL, W-2 wages, or rate of pay. It’s possible that the IRS will issue future guidance to align the safe harbors with the individuals’ threshold. We’ll have to wait and see — again.

Tracy Watts
by Tracy Watts

Senior Partner, National Leader for U.S. Health Policy

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