ACA Compliance Validation (ACV) System: Ready for Prime Time?

ACA “repeal” proposals at this point seem like zombie extras – walking dead, and none of them purports to repeal employer mandate taxes that accrued in 2015. Collection is coming; only the timing is in question. ACV 2.0 is the program designed in 2015 to enable the IRS to identify, starting in early 2017, non-compliant Applicable Large Employers.  View Full Post
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M.C. Escher and Erwin Schrodinger Walk into a Bar … or Are They Walking Out? and How Can the CBO Be Sure?

The pundits and political partisans apparently stopped reading before the heading on page 9 of the CBO’s June 26 report on the Better Care Reconciliation Act (BCRA) Discussion Draft, “Uncertainty Surrounding the Estimates,” which the CBO conceded to be “inherently inexact,” given the complexity of possible reactions to BCRA passage.  View Full Post
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Hull Speed, Codgers, and Pre-Existing Conditions: What Does the Senate Bill Do?

Many other things being equal, the longer the sail boat, the faster it can go before its bow wave defeats further speed increase.  However, as any boat approaches its “hull speed,” an increasing amount of energy is required to add each new increment of speed.    View Full Post
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Get Ready for “On the Motion to Amend the Amendment of the Amendment of the Amendment …”

The “Discussion Draft” released June 22, 2017 by the Senate Budget Committee carries the House Bill number (H.R. 1628) of the American Health Care Act, and kills taxes like the House bill, but there are major differences, too.  At 142 pages, the Discussion Draft is less than one-sixth the heft of the ACA but it’s a brutal read.  View Full Post
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“but Officer, He Came Out of Nowhere!”

Lots of wrecks happen because drivers, staring at what’s directly in front of them, are unaware of dangers coming from other directions. This is an ACA blog, so right now we’re staring at the ACA changes being proposed by the Senate majority, but we want you to remain aware that collateral developments could spell trouble for your group health plan.  View Full Post
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Updated Employer Mandate Tax Assessment Guidance: “Would You Believe …?”

Maxwell Smart, aka “Agent 86” in the 1960’s TV series Get Smart, claimed to have survived “fiendish” water torture – 300 gallons at the rate of one drop a minute.  When disbelieved, he asked, “Would you believe a quart?”  The IRS has a similar credibility problem.  View Full Post
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May the 4th Be with You

And if you are an ACA “Applicable Large Employer” (ALE), it was. The American Health Care Act, H.R. 1628, with last minute amendments noted in H. Rep. 115-109, passed the House of Representatives on Thursday afternoon, May 4.  Here is a very brief summary of the 131 pages of combined text, focused on changes for Applicable Large Employers. View Full Post
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