This is from Towers Watson:
[P]reliminary guidance [provides that] applicable coverage would include coverage under both fully insured and self-insured employer-sponsored health plans, regardless of who pays for the coverage or whether it is paid for with pretax or aftertax dollars. Applicable coverage would include (non-exhaustive list):
- Employer and employee contributions to major medical coverage excludable from employees' gross income
- Employer and employee contributions to health flexible spending accounts (FSAs)
- Employer contributions (including employee pretax salary reduction contributions) to health savings accounts (HSAs) and Archer medical savings accounts
- Health reimbursement arrangements (HRAs)
- Onsite medical clinics (except for those providing only de minimis medical care, such as free first aid to employees)
- Retiree coverage
- Executive physical programs ...
