From: Carlton Harker, April 5, 2016
IRS Notice 2014-69 provides that the so-called Minimum Benefit Plans will fail the Minimum Value Test, unless they provide “substantial” hospital and physician benefits.
An IRS regulation/ruling was to have been issued in 2015 but has not. Until a clarification of the meaning of substantial, the preferred course of action is to mark time. Any non-compliance penalties will be waived during this wait time.
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