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ABC, as part of the Employers for Flexibility in Health Care (EFHC) coalition, submitted comments on provisions in the Patient Protection and Affordable Care Act (PPACA) regarding the health insurance premium tax credit; eligibility determinations and exchange standards for employers; and the health coverage affordability safe harbor for employers. 

The comments were submitted to the Internal Revenue Service and the Department of Health and Human Services in an effort to help ensure employer-sponsored coverage remains a competitive option for all employees whether full-time, part-time, temporary, or seasonal workers. 

In the comments, the coalition expressed concern that the employer requirements under PPACA are fundamentally unworkable and ultimately will have to be re-examined through the legislative process. The coalition called special attention to the definition that says employees who work 30 hours per week are considered full time, the affordability and minimum value standards for employer coverage, the imposition of tax penalties based on a household income, the complex administrative reporting requirements, and the authority given to state insurance exchanges over employer-sponsored plans. 
The coalition pointed out the interplay of the employer requirements under the law has significant consequences for employers’ ability to maintain flexible work options and affordable health coverage for their employees. Because the employer requirements are inextricably linked, it is imperative that the administration examine these provisions as a whole when developing regulatory guidance, wrote the coalition. 

The EFHC also mentioned that the businesses it represents employ large, fluctuating workforces and often offer consumer goods and services with low profit margins, meaning even small increases in premium costs could force their businesses to stop offering coverage, forgo hiring new employees, reduce employee hours to part-time status or raise consumer prices.  

“The coalition is working hard to propose regulatory solutions that make coverage affordable for both employers and employees,” the comments stated. “We want to be able to offer the most comprehensive coverage possible at a price that is affordable for and tailored to our specific workforces.” 

For more information on these comments or PPACA, contact Karen Livingston at ABC, [email protected].