IRS Issues Notice Regarding PPACA Excise Tax

Part of the Patient Protection and Affordable Care Act (“PPACA”) efforts to reduce healthcare costs include an excise tax on health insurers that provide benefits to employees above a threshold limit. This tax is designed to discourage insurance programs that allow employees to receive unusually generous benefits under the insurance plan, which is believed to encourage heavy usage of healthcare. By reducing the overall usage, it will decrease costs. Moreover, it is expected that this tax will help fund the PPACA and off-set the cost of healthcare for those who are not enrolled in a qualified welfare plan. The 40% excise tax is set to take effect in 2018 for the cost of an applicable coverage plan that is above the threshold limit.

In preparing for the implementation of the excise tax, the Internal Revenue Service (“IRS”) has issued Notice 2015-16. This notice serves to clarify “the definition of applicable coverage,” “the determination of the cost of applicable coverage,” and “the application of the annual statutory dollar limit to the cost of applicable coverage.” The notice also seeks input on these issues.

This notice is only the start of implementing the new excise tax and the IRS anticipates issuing further notices. Eventually, the IRS intends to propose regulations and will invite further comments. For details regarding Notice 2015-16, the notice may found at the following link: .

© 2015 Houghton Vandenack Williams

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The Impact of the Supreme Court’s Healthcare Ruling on Physicians

The Supreme Court’s ruling recently upholding the constitutionality of the PPACA signals the continuing expansion of the U.S. healthcare system.

The PPACA extends care to approximately 50 million formerly uninsured individuals.  The uninsured currently forgo many, if not all, of the preventative procedures available.  This will surely change as the PPACA is implemented. Although all physicians will likely see an increase in patients, the majority of the demand will be borne by primary care providers (PCPs), likely without the assistance of an increase in physicians providing primary care services.

To meet the increase in demand, physicians should start looking for investments that will increase efficiency.  As time passes, healthcare reform initiatives like EHR, ACOs, and new physician reimbursement models may become more important for physicians trying to keep up with growing demand.  Individuals providing complementary services–nurse practitioners and physicians’ assistants–are also likely to play an increasingly more significant role going forward as providers look to cut costs.

The Department of Health and Human Services (HHS) recognizes the challenges physicians face as implementation of the PPACA progresses. Signaling primary care as a central focus of the legislation, HHS recently proposed increasing Medicaid reimbursements to Medicare levels for PCPs during 2013 and 2014.  The proposal is expected to boost reimbursements by an average of 34%, incentivizing PCPs to begin preparing for the influx of new patients.  The PPACA also seeks to facilitate the expansion of services into underserved areas by increasing payments to rural healthcare providers.

Although some uncertainty still exists, one thing is certain–physicians need to start taking proactive steps to address the significant expansion of demand for their services.

© 2012 Parsonage Vandenack Williams LLC

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