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IRS Notice Requests Comments on Minimum Value and Reporting Requirements for Group Health Plans
McDermott Will & Emery
[Guidance Overview] May 7, 2012
"The [IRS is requesting comments on] three potential approaches to determining minimum value under consideration: 1. Use of an actuarial value calculator (for insured small group plans) or minimum value calculator (for self-insured and insured large group plans) created by [HHS] and the Treasury ... 2. Creation of various design-based safe harbor checklists describing deductibles, co-pays, coinsurance, out-of-pocket maximums and other cost-sharing attributes for the four core categories of benefits and services [and] 3. For non-standard plan designs, determination by a certified actuary that the plan provides minimum value."
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