Down to the Wire Guidance on Minimum Value Plans

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Down to the Wire Guidance on Minimum Value Plans
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Calendar05 November 2014

As employers are in the throes of open enrollment, the IRS issued guidance on requirements for minimum value plans. This guidance comes after a reported "glitch" in the HHS minimum value calculator that made it possible for a plan to obtain a minimum value of 60% while excluding coverage for hospital inpatient services. This most recent guidance states that plans that don't include coverage for hospital inpatient services or physician services (or both) won't qualify as minimum value coverage in 2015. Due to the late notice, employers with plans that were able to comply due to the glitch and are in a binding contract will be allowed for the 2015 plan year. The good news is that employees who qualify for subsidized coverage and want to sign up for more comprehensive coverage in the public exchange will be allowed to do so and their employer will not be penalized. So, a win on both accounts. Employers are required to communicate to employees on this issue if such a plan has been offered. Expect vendors with these products to respond accordingly with enhanced plan designs for 2016.  

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