Commenters: Calculation of ‘Minimum Value' a High-Stakes Proposition

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Employer and employee groups urge the Treasury Department and IRS to settle for nothing less than a fair, accurate “minimum value” assessment of employer-sponsored health plans, with each side citing the high stakes for employers and employees in recent public comment letters. On calculating “minimum value,” the Employers for Flexibility in Health Care Coalition—representing retail, restaurant, hospitality, and other service industries—says employers “are anxious to know where they fall in comparison to what is currently a blackbox,” a statement reflecting the uncertainties that a variety of groups expressed. EFHC Coalition and other employer groups submitted detailed comments on IRS's draft proposal in Notice 2012-31, which described three alternative methods that insurers and group health plans could use for determining “minimum value” and avoiding employer penalties for not meeting the minimum value standard of the Patient Protection and Affordable Care Act.