As you may know, in order to avoid penalties under the Affordable Care Act (“ACA”), large employers must offer their full-time employees coverage that is affordable and meets minimum value (“MV”). Some vendors exclude certain core benefits, such as in-patient hospitalization and/or physician services from their plans (referred to as “Narrow MVPs”) and use the MV Calculator to determine that the Narrow MVPs meet MV under the ACA. The vendors claim the Narrow MVPs insulate employers from penalty exposure and preclude employees from accessing subsidies in the Marketplace. There has been much controversy as to whether the Narrow MVPs do, in fact, satisfy the MV requirement.
On November 4, 2014, the Departments of Health and Human Services, the Treasury, and Internal Revenue Service (collectively, “the Departments”) put an end to the uncertainty. The Departments announced their intent to issue regulations clarifying that a group health plan will not provide MV if it excludes substantial coverage for in-patient hospitalization services or physician services (or both).
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As always please contact your Total Benefit Solutions account manager if you have any questions or concerns regarding this bulletin. (215)355-2121.