IRS Issues Notice on PPACA “Cadillac” Tax

On July 30, 2015, the Internal Revenue Service (IRS) issued Notice 2015-52, addressing issues and seeking public comments on the implementation of the “Cadillac” tax on high-cost health insurance under the Patient Protection and Affordable Care Act (“PPACA”).  The Cadillac tax is intended to discourage expensive health care plans by imposing a non-deductible 40 percent excise tax on the portion of health plan costs that exceed a predetermined dollar amount.  The tax, which will go into effect in 2018, generally applies to healthcare benefit packages costing more than $10,200 for individuals and $27,500 for families, subject to certain proposed adjustments.  Although the law was passed in 2010, many details of how the tax will be implemented still remain to be sorted out.

For example, one of the basic issues with the Cadillac tax is determining who has the responsibility to pay it.  The law provides that the tax must be paid by the “coverage provider.” Depending on the circumstances, that may be the insurance company, the employer or “the person that administers the plan benefits.”  However, some key terminology impacting these determinations have yet to be defined.  Other unresolved complexities addressed the in IRS notice include: timing issues relating to calculation and payment of the tax, circumstances under which employers will be aggregated for purposes of the tax, and adjustments to the dollar limit based on age and gender.

The IRS has invited public comments on the issues raised in the Notice, as well as any other issues relating to the Cadillac Tax.  Public comments are due no later than October 1, 2015.  Comments received will be used in the preparation of forthcoming Treasury Regulations governing the Cadillac tax.

Notice 2015-52 is available at the following link:

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Earlier this year, the American Medical Association (“AMA”) established a new online learning center to provide physicians with the information and tools that they need to make well-informed decisions about electronic prescribing (“ePrescribing”).  Now, the AMA has introduced additional enhanced tools for ePrescribing. 

The learning center offers many tools and resources to help physicians, including calculators to estimate time savings and eligibility for incentive payments as well as planning devices to help assess practice readiness for and ease implementation of new technologies.  Examples of some of the new tools include:

  • A system finder tool that picks three systems for a user based on the user’s response to a brief survey
  • Side-by-side comparisons of up to three sPrescribing vendors at one time
  • The ability to view vendor feedback and ratings from other users, and the ability to provide one’s own feedback
  • Automated capability to contact a vendor when a decision is reached

The site and its resources can be accessed by physicians and others at

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