"[The Chamber] strongly recommends that the safe harbor concept be broadened ... Given that only two percent of individuals were then covered by plans which failed to meet the 60 percent actuarial value threshold, it will be an even smaller percentage once these plans are outlawed.... [Also, the Chamber disputes] the position taken in this Notice (and in the Actuarial Value and Cost-Sharing Reduction Bulletin by the Department of Health and Human Services) that, when calculating the minimum value of the contribution made by the employer to an HSA or HRA, only a portion or 'appropriate amount' of these employer contributions would be credited to the actuarial value calculation. Instead, the entire amount of the employer contributions should be included."  MORE >>