NADP and the Commission on Advocacy Policy (CAP) submitted comments in response to IRS proposed guidance regarding
the “Excise Tax on High Cost-Employer Sponsored Health Coverage,” which
is also known as the “Cadillac Tax.” The proposed guidance would
implement the Affordable Care Act’s (ACA) 40% tax on employers that
provide high-cost health benefits to employees, and as currently
drafted, questioned whether the tax should exclude HIPAA-excepted
benefits from the calculation of the tax.

In comments,
NADP supported the Treasury and Internal Revenue Service (IRS) approach
within the Notice to clarify both Health Insurance Portability and
Accountability Act (HIPAA)-excepted insured and self-insured standalone
dental coverage should be exempted from the excise tax on high cost
employer coverage. As nearly half of all group dental benefits are
self-insured, NADP observed that allowing for equality regardless of how
the benefits are administered is necessary to keeping the commercial
market consistent.

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