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That's a Wrap! The ACA Creates a New Excepted Benefit
Hill, Chesson & Woody Link to more items from this source
[Guidance Overview]
Jan. 20, 2014
"The proposed regulations describing Limited Wraparound Coverage begin with the assumption that employer-sponsored major medical plans are better than any plan an individual can purchase through the Marketplace ... [and] then assume that some employees will not be able to afford the employer-sponsored plan, will waive the coverage and instead purchase coverage in the Marketplace that costs less. In such a case, the employer might then be inclined to offer 'wraparound coverage' ... [which,] together with the Marketplace coverage, would be comparable to the employer-sponsored plan. Making all of this possible is the proposed rule that the wraparound coverage, subject to certain requirements, would be considered an excepted benefit and not subject to the market reform requirements of the ACA."

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