Our significant recommendations to the IRS included:
- All wellness incentives should be taken into account for affordability purposes, not just those related to tobacco use.
- A safe harbor should be available for plans that have copayments.
- If included in the final regulation, the IRS should provide statutory justification for the assertion in the preamble that employers may not cover employees in an employer-sponsored health plan unless the employee may opt out of coverage.
- Stand-alone HRAs should not be considered minimum essential coverage for pre-Medicare eligible retirees under specified circumstances.
ERIC’s comment letter is available here.
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