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Actuarial Value Subgroup of the American Academy of Actuaries Comment Letter to IRS on IRS Notice 2012-31, 'Minimum Value of an Employer-Sponsored Health Plan' (PDF)
American Academy of Actuaries Link to more items from this source
June 12, 2012

"[While] the subgroup does not expect non-core benefits to have a large effect on the MV calculations ..., the methods for including non-core benefits in the MV calculation must be considered carefully, otherwise unintended conclusions could result. And importantly, information regarding the degree to which non-core benefits are included in the data underlying the MV calculator needs to be made available to actuaries performing MV calculations... Plans not meeting safe harbor requirements potentially could meet MV requirements through use of the MV calculator or through separate actuarial certification."

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