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Employment, Labor & Benefits Advisory: Battle of the Comments under Code § 36B



11/28/2011

By Alden J. Bianchi

Comments submitted in response to proposed rules implementing the Affordable Care Act’s health insurance premium tax credits for low-income individuals have exposed a rift between consumer and industry groups concerning the “affordability” of, and the “minimum value” provided by, employer-sponsored group health insurance. Both affect the circumstances under which access to employer-sponsored group health plan coverage will bar individuals and their families from qualifying for premium tax credits. This advisory examines this rift and its consequences.

» Click here to read the full advisory.

 

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