A proposed regulation implementing a $101 billion health insurance fee imposed by the Affordable Care Act amounts to double taxation, health insurers told the Internal Revenue Service (IRS) in comments filed June 3.

The health insurance fee, which takes effect in 2014 and will raise an estimated $101 billion over 10 years to help pay for ACA's premium subsidies and other costs, "appears to double tax consumers and employers," Aetna said in its letter. The fee is not deductible for tax purposes, meaning insurers will need to raise premiums by $1.54 for every $1 in fees, Aetna Senior Vice President Steven Kelmar said.

America's Health Insurance Plans (AHIP) has called for repealing the fee. In its comment letter, AHIP suggested that IRS follow recommendations made by law firm Skadden Arps to lessen the impact of the fee. One of those recommendations was to allow insurers to exclude premiums needed to cover the fee when reporting gross income.