Friday, May 15, 2015

2018's Cadillac Tax Slated to Gouge Both Fully Insured and Self Funded Plans

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 ...