6 pages. "The Council is very concerned about the Proposed 2016 [Notice of Benefit and Payment Parameters (NBPP)] as it relates to the definition of 'minimum value' to the extent the same or a similar definition becomes applicable for purposes of Code sections 36B and 4980H ... [We] are concerned that the expanded definition, as proposed, is contrary to the statutory language of the [ACA] as well as congressional intent. Moreover, we believe the rule, if adopted, would serve to further exacerbate employer concerns regarding the application of the 40 percent high-cost excise tax (i.e., the 'Cadillac Tax) to their employer-sponsored plans. For these reasons, we strongly oppose the proposed expansion of the minimum value definition."