Recent Health Care Reform Questions

We’ve been receiving many questions via our recent Advanced Health Care Reform webinars. Below is an example of the question and our response.

Can the HSA amount the employer contributed be counted toward the cost of affordable/adequate healthcare to get the 9.5%?

Question: Can the HSA amount the employer contributed be counted towards determining whether a health plan is affordable (i.e. whether the employee premiums exceed 9.5% of household income)?

Response: No – HSA contributions are for out of pocket expenses and cannot be counted toward determining whether a health plan is affordable (i.e. whether the employee premiums exceed 9.5% of household income).

Question: Can the HSA amount the employer contributed be counted towards determining a health plan’s actuarial value?

Response: Yes – “first dollar” employer funded HSA contributions (i.e. employer HSA contributions which allow the employee to use those funds toward deductibles right away as out of pocket expenses are incurred) will count towards determining a health plans underlying actuarial value

Additional Insight: A health plan with a $0 deductible will have the same AV percentage as a plan with a $1,000 deductible that has an associated HAS or HRA with a current year $1,000 employer contribution – which comes out of the regs (204.19 | see attached).

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