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Partnership for Employer-Sponsored Coverage Comment Letter to Agencies on Proposed Rules to Expand HRAs (PDF)

"The Partnership remains concerned about the level of complexity, costs and burdens that may be associated with the verification and notification processes referenced in the proposed rule regarding the offer of an HRA for [individual healthcare coverage] purchase. The current ACA 6055 and 6056 reporting burdens loom large over employers and any additional burdens resulting from a new verification and notification process under the proposed rule may deter employers from offering coverage all together."

Partnership for Employer-Sponsored Coverage Letter to Congress in Support of the Primary and Virtual Care Affordability Act (HR 5541) (PDF)

"Telehealth has served as an essential lifeline to care for millions of Americans during the pandemic, especially those seeking behavioral and mental health services. Extending this policy and covering in-person primary care visits will provide a continuity of care beyond 2021."

Partnership for Employer-Sponsored Coverage Comments to Senate HELP Committee on Rising Health Costs

"Eliminating or capping the tax exclusion of employer-sponsored coverage for individuals has been seen as a way to raise federal revenue and/or offset the cost of other federal reforms or programs ... A cap on the exclusion does not address rising health system costs or utilization and will stifle private-sector innovation and delivery designs ... There is no one-size-fits-all employer health plan nor should the federal government enact or implement laws that stifle an employer's ability to develop benefits offerings that meet the needs of their specific workforce[.]"

P4ESC Letter to Congress Opposing Cap on Tax Exclusion for Employer-Sponsored Coverage (PDF)

"Employers and employees covered by their health plans differ by size, workforce composition and by region. The task of designing a cap on the exclusion for all employer-sponsored plans would be very difficult.... [No] matter how carefully crafted a cap on the tax exclusion may be, there is no logical limiting principle to a cap. Future Congresses could well return to the tax exclusion to generate additional savings. Once the principle of a cap on the exclusion is established, a future Congress could dial the cap ever downward."

P4ESC Letter to Congress Supporting Employer-Sponsored Coverage (PDF)

"P4ESC would like to highlight the following principles and priorities that are important to ensuring that employment-based coverage thrives into the future. [1] Preserve and strengthen employer-sponsored health coverage. [2] Address medical costs and challenges to help keep coverage affordable. [3] Uphold the current tax-treatment of employer-sponsored coverage. [4] Provide employers with compliance relief from burdensome regulations governing health coverage. [5] Promote innovations and diversity of plan designs and offerings for employees."

P4ESC Comment Letter on IRS Notice 2020-76: Transition Relief Related to Health Coverage Reporting Required by Sections 6055 and 6056 for 2020 (PDF)

15 pages. "[The Partnership for Employer-Sponsored Coverage (P4ESC) strongly urges] the new Administration to: ... [1] Revise the list of data requirements under sections 6055 and 6056 to be relevant and practical ... [2] Decouple information reporting for sections 6055 and 6056 from Form 1095-C.... [3] Enable applicable large employers (ALEs) to prospectively report to the IRS relevant data items about the type of coverage offered to their workforce of full-time employees ... prior to open enrollment season in the Exchanges ... [4] Eliminate the requirement that self-insured employers send an individual 1095-C form to all enrolled employees.... [5] Require review of ALE-filed data before a 226-J penalty notification letter is sent.... [6] Provide employers with 90 days, rather than 30 days, to appeal a 226-J tax penalty letter for any tax compliance year.... [7] Work directly with HHS and state-based Exchanges to verify employer information during open enrollment to determine individual premium tax credit eligibility."

P4ESC Letter to Congressional Leaders Promoting Employer-Provided Health Coverage (PDF)

"We urge Congress to find ways to strengthen employer-sponsored coverage rather than to search for alternatives to it.... [T]he following principles [are] important to ensuring that employment-based coverage thrives into the future: [1] Uphold the current tax treatment of employer-sponsored coverage. [2] Preserve ERISA preemption -- the vital backbone of employer-sponsored coverage. [3] Address rising medical costs and market dysfunctions to help keep care and coverage more affordable."

P4ESC Statement to House HELP Subcommittee Hearing on Expanding Access and Affordability in Employer-Sponsored Health Care (PDF)

"P4ESC urges your attention to the following principles that are important to ensure that employment-based coverage thrives into the future: [1] Uphold the current tax treatment of employer-sponsored coverage; [2] Preserve ERISA preemption -- the vital backbone of employer-sponsored coverage; [3] Address rising medical costs and market dysfunctions to help keep care and coverage more affordable."

P4ESC Letter to Agencies on Timelines and Obligations for Implementation of the Transparency in Coverage Final Rule (PDF)

"[P4ESC is] very concerned about employers' ability to comply with the machine-readable files requirement by January 1, 2022... Because the employer does not own this network and drug pricing information, they must request it from the TPA/PBM or request that the TPA/PBM directly provide a compliant solution on the employer's behalf. The employer is at the mercy of the TPA/PBM's prerogative and schedule to obtain the information or provide a compliant solution."

P4ESC Health Policy Priorities (PDF)

"ERISA uniformity is important to maintain common benefit coverage for employees in multiple states. But it is also vitally important to finding economies of scale in benefit administration.... To tamper with the current tax treatment of employer-sponsored coverage would be especially devastating to businesses and American workers. It would also fail to address the cost drivers behind rising health care costs."