"[I]f the employer also offers employees an 'opt-out' payment for those who decline coverage, then this opt-out amount must be counted as part of the employee contribution, according to informal discussions with [IRS] representatives.... While this impact of cash opt-out payments on affordability is not clearly articulated in the Section 4980H regulations, [this IRS] position ... is consistent with the final regulations relating to the requirement to maintain minimum essential coverage and makes sense from an economic standpoint.... [The IRS] also stated informally that it may treat similar cash payments to Service Contract Act and Davis-Bacon Act employees differently."  MORE >>