NADP and the Commission on Advocacy Policy (CAP) are drafting 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 ACA’s 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. NADP will support the proposal to exclude
the costs of fully-insured and self-insured standalone
dental benefits in calculating the tax. Draft comments will be posted to
Dental Interact this week. Public Comments are due May 15.

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