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Beginning the Regulatory Conversation About the Cadillac Tax
Timothy Jost, in Health Affairs ForefrontLink to more items from this source
[Guidance Overview]
Feb. 24, 2015

"Under the approach to the rule that the IRS is considering, an employer would begin by aggregating all employees who are covered by a particular benefit package, such as a high- or low-option or HMO or PPO plan. Those groups would then be disaggregated into self-only and other-than-self-only coverage. Beyond this, the IRS is considering allowing (but not requiring) health plans to further disaggregate members either based on bona-fide occupation-related criteria (not including health status), or based on a limited number of specific criteria the IRS might list, such as number of individuals in unit, geographic location, or current and former employees. Comments on these different approaches are requested, although since rules applied are supposed to be similar to COBRA rules, the IRS suggests that if it makes changes to these rules it might change COBRA rules as well."

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