IRS Notice 2015-87 (“the Notice”) provided guidance in the form of questions and answers on certain group health plan provisions of the Affordable Care Act (ACA). ErisaALERT 2016-01 discussed the impact of opt-out incentives on ACA affordability. This ALERT discusses the impact of employer HRA contributions and flex credits on ACA affordability. Quick overview of […]
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Affordability
The Impact of Opt-out incentives on ACA Affordability Calculations
The question had arisen on how to treat opt out incentives. By that we mean a monetary offer by an employer to employees to waive coverage under the employer’s health plan. Informal IRS comments had indicated that such incentives would be included when determining whether an offer of coverage is affordable. There are generally two […]
ACA, Affordability, Affordable Care Act, Incentives, opt-out incentives