A significant challenge for employers that sponsor a worksite clinic is having to charge a “Fair Market Value (FMV)“ fee for non-preventive or wellness medical services provided before a high deductible is met to employees or their dependents who have Health Savings Accounts (HSAs). If a FMV fee is not charged, the employee may lose their eligibility to contribute to their HSA. This has been a barrier for employees, especially low-wage workers with HSAs, to obtain services when an out-of-pocket payment is required, even if the employer doesn’t charge employees with other types of health benefit coverage for using the health center.
The National Association of Worksite Health Centers (NAWHC) has been active in trying to repeal or modify IRS rules in this area and recently formed the Fair Market Value Collaborative (FMVC). The FMVC is a partnership of NAWHC, The ERISA Industry Committee (ERIC), employers, vendors and other interested parties. The Collaborative has drafted a sign-on letter to the Congressional leadership to support their effort for FMV relief. Review the letter and, if you agree with the need to make a change, sign on. Feel free to share this letter with others who will support the cause.