Health >> Health Care Reform (PPACA) >> Tax, Fee & Revenue Issues


Legislative — proposals, bills and analysis from 2006-present

Regulatory — administrative rules and information from U.S. offices and agencies

Judicial — current and past court cases and amicus briefs

Archive — Click to access archived items for this issue

Press Releases — Council statements and advisories to the news media

See Also — for related information

Related Links — for related links



(Items in italic are available only to Council members.)

Official Source Documents

July 8, 2016 — IRS NPRM on ACA Premium Tax Credit VI

December 18, 2015 — IRS Final Regulations on Minimum Value of Eligible Employer-Sponsored Plans and Other Rules Regarding the Health Insurance Premium Tax Credit

July 30, 2015 — IRS Notice 2015-52 on Section 4980l Excise Tax on High Cost Employer-Sponsored Health Coverage

March 30, 2015 — IRS Notice 2015-29: Application of Health Insurance Providers Fee to Expatriate Plans

February 27, 2015 — HHS/CMS Final Regulations on Notice of Benefit and Payment Parameters for 2016 including Transitional Reinsurance Fee

February 23, 2015 — IRS Notice 2015-16: RFI on the 40% Excise Tax on High Cost Employer-Sponsored Health Coverage

September 19, 2014 — IRS Notice 2014-56: Adjusted Applicable Dollar Amount for PCORI Fee

May 22, 2014 — CMS Guidance on Reinsurance Contributions Process

March 11, 2014 — HHS Final Regulations: Notice of Benefit and Payment Parameters for 2015 including Transitional Reinsurance Fee

December 2, 2013 — HHS Notice of Benefit and Payment Parameters for 2015 including Transitional Reinsurance Fee

October 30, 2013 — CMS Final Rule on Exchange, Premium Stabilization Programs and Market Standards; Amendments to the HHS Notice of Benefit and Payment Parameters for 2014 (Including Guidance on Transitional Reinsurance Program)

July 25, 2013 — IRS Questions and Answers on Payment of PCORI Fee

May 3, 2013 — IRS Proposed Regulations on Minimum Value of Eligible Employer-Sponsored Plans, Health Insurance Premium Tax Credit (Section 36B)

March 11, 2013 — HHS Notice of Benefit and Payment Parameters for 2014: Interim Final Regulations and Amendments to Risk Adjustment, Transitional Reinsurance, and Risk Corridors Programs; Cost-Sharing Reductions; User Fees for Federally-Facilitated Exchanges; Advance Payments of the Premium Tax Credit; the Federally-Facilitated Small Business Health Option Program; and the Medical Loss Ratio Program

March 11, 2013 — HHS Notice of Benefit and Payment Parameters for 2014: Final Regulations on Risk Adjustment, Transitional Reinsurance, and Risk Corridors Programs; Cost-Sharing Reductions; User Fees for Federally-Facilitated Exchanges; Advance Payments of the Premium Tax Credit; the Federally-Facilitated Small Business Health Option Program; and the Medical Loss Ratio Program

March 4, 2013 — IRS Proposed Regulations Regarding PPACA Health Insurance Providers Fee

February 1, 2013 — IRS Final Regulations on Health Insurance Premium Tax Credit under PPACA

December 7, 2012 — HHS Proposed Regulations on Benefit and Payment Parameters under PPACA (Including Transitional Reinsurance Fee)

December 6, 2012 — IRS Final Regulations on Fees on Health Insurance Policies and Self-Insured Plans for the Patient-Centered Outcomes Institute (PCORI) Research Trust Fund

December 5, 2012 — IRS Notice of Proposed Rulemaking on Additional Medicare Tax

November 30, 2012 — IRS Frequently Asked Questions on Transitional Reinsurance Program

November 30, 2012 — IRS Notice of Proposed Rulemaking on Net Investment Income Tax

August 15, 2012 — Council Special Alert: PPACA Transitional Reinsurance Fee to be Assessed on Insured and Self-Insured Health Plans

July 12, 2012 — Corrections to Final Regulations - IRS Final Regulations on Health Insurance Premium Tax Credit under PPACA

May 31, 2012 — HHS Bulletin on the Transitional Reinsurance Program: Proposed Payment Operations

May 23, 2012 — IRS Final Regulations on Health Insurance Premium Tax Credit under PPACA

April 17, 2012 — IRS Proposed Regulation on Funding of Patient-Centered Outcomes Research Trust Fund

March 23, 2012 — HHS Final Regulations on Reinsurance, Risk Corridor and Risk Adjustment Standards under PPACA

March 23, 2012 — HHS Presentation/Summary of Final Regulations on Reinsurance, Risk Corridor and Risk Adjustment Standards under PPACA

August 17, 2011 — IRS Notice of Proposed Rulemaking on the Health Insurance Premium Tax Credit

August 12, 2011 — IRS Fact Sheet on the Health Insurance Premium Tax Credit NPRM

June 9, 2011 —  IRS Notice 2011-35 on Comparative Effectiveness Program Fees

April 1, 2011 — FAQs on PPACA Implementation Part VI

Council Materials

June 1, 2016 — Council Highlights from May 2016 Regulatory Agendas

December 18, 2015 — Highlights from the Obama Administration’s October 2015 Regulatory Agendas and IRS Priority Guidance Plan

October 1, 2015 — Alliance to Fight the 40 Letter to IRS Regarding Notice 2015-52: Section 4980l Excise Tax on High Cost Employer-Sponsored Health Coverage

October 1, 2015 — Council Letter to IRS Regarding Notice 2015-52: Section 4980l Excise Tax on High Cost Employer-Sponsored Health Coverage

September 3, 2015 — Benefits Briefing Presentation Slides: IRS Notice 2015-52: 40% Excise Tax on High-Cost Health Coverage (Seth Perretta, Groom Law Group)

August 31, 2015 — BENEFITS BLUEPRINT: The 40 Percent Tax on Health Benefits Effective in 2018: Overview of Notice 2015-52 (Prepared by Rachel Levy, Allison Ullman and Seth Perretta of Groom Law Group)

May 15, 2015 —  Council Letter to IRS Regarding Notice 2015-16: RFI on the 40% Excise Tax on High Cost Employer-Sponsored Health Coverage

May 15, 2015 — Results of the Council's Survey on the 40 Percent Excise Tax on High-Cost Health Coverage

April 7, 2015 — Benefits Briefing Presentation Slides: IRS Notice 2015-16: 40% Excise Tax on High-Cost Health Coverage (Seth Perretta, Groom Law Group)

March 30, 2015 — Frequently Asked Questions (Updated): 40 Percent Excise Tax on High-Cost Employer-Sponsored Health Coverage

March 26, 2015 — BENEFITS BLUEPRINT (Updated): The 40 Percent Excise Tax on High-Cost Employer-Sponsored Health Coverage Effective in 2018 (Prepared by Allison Ullman, Seth Perretta, and Malcolm Slee of Groom Law Group)

September 18, 2014 — BENEFITS BLUEPRINT: The 40 Percent Excise Tax on High-Cost Employer-Sponsored Health Coverage Effective in 2018 (Prepared by Allison Ullman, Seth Perretta, and Malcolm Slee of Groom Law Group)

September 18, 2014 — Frequently Asked Questions: 40 Percent Excise Tax on High-Cost Employer-Sponsored Health Coverage

July 24, 2014 — P4P Presentation Slides: 40% Excise Tax on High-Cost Health Coverage (Seth Perretta, Groom Law Group, & Tracy Watts, Mercer)

April 4, 2013 — BENEFITS BLUEPRINT: Summary of HHS Final Regulations Addressing Transitional Reinsurance Fee (Prepared by Seth Perretta, Allison Ullman and Via Boppana of Crowell & Moring LLP)

December 31, 2012 — Council Comments to HHS Regarding Proposed Regulations Addressing Transitional Reinsurance Fee

December 12, 2012 — Summary: Treasury, IRS Release Final PCORI Fee Regulations (Prepared by Crowell & Moring)

December 12, 2012 — Benefits Briefing Presentation Slides: Transitional Reinsurance and PCORI Fee Regulations (Seth Perretta, Crowell & Moring)

December 12, 2012 — Summary: HHS Releases New Proposed Regulations Regarding Transitional Reinsurance Program (Prepared by Crowell & Moring)

October 2, 2012 — Council Comments to CCIIO Regarding Implementing Standards Related to the Transitional Reinsurance Program

August 6, 2012 — Summary of Transitional Reinsurance Program Guidance within HHS Final Regulations on Reinsurance, Risk Corridor and Risk Adjustment Standards under PPACA(Prepared by Crowell & Moring LLP)

July 16, 2012 — Council Comment Letter to IRS Regarding Proposed Regulation on Funding of Patient-Centered Outcomes Research Trust Fund

April 10, 2012 — Summary of Transitional Reinsurance Program Guidance within HHS Final Regulations on Reinsurance, Risk Corridor and Risk Adjustment Standards under PPACA(Courtesy of Crowell & Moring LLP)

October 31, 2011 — Council Comment Letter Regarding IRS NPRM on Health Insurance Premium Tax Credit under PPACA

September 6, 2011 — Council Comment Letter to IRS Regarding Notice 2011-35, Request for Comments on Funding of Patient-Centered Outcomes Research

Official Source Documents
Council Materials

April 14, 2016 — Employer innovations in health care coverage rely on regulatory flexibility, smart tax policy
March 23, 2016 — Nationwide poll shows voter support for lawmakers who vote to repeal “Cadillac Tax,” strong skepticism of proponents’ claims
December 18, 2015 — Council applauds House approval of provision to delay ‘Cadillac Tax,’ urges Senate to follow suit
December 18, 2015 — House, Senate delay of health care ‘Cadillac Tax’ a critical first step toward full repeal
December 16, 2015 — Council urges Congress to pass “Cadillac Tax” delay included as part of year-end legislation
September 17, 2015 — nr2015-18_heller_cadillac_bill_intro_print_091715.pdf