"The IRS has been publicly discouraging use of non-hospitalization/physician services plans for months leading up to the issuance of Notice 2014-69, and the timing of the release (election day) was likely no coincidence. The only unanswered question was whether the IRS would 'grandfather' plans that had already adopted this approach. It appears employers who got in the door before election day will receive a free pass for a year before being forced to expand coverage or explore other options in 2016. It also appears that the IRS still hopes to make a premium tax credit or subsidy available to employees offered such a MV plan this year."