On August 31, 2015, the IRS proposed a modification to the definition of what constitutes minimum value under the Affordable Care Act. This modification follows IRS Notice 2014-69, which was issued in November of 2014 after the IRS became aware that plans without inpatient hospital coverage and/or physician services were being marketed to employers as providing “minimum value.”As expected, following that 2014 Notice, the new proposed definition requires that a plan provide substantial inpatient hospital services and physician services (and meet the 60% rule) to be deemed to provide minimum value. For purposes of the employer penalty rules, these rules do not apply before the end of the plan year that begins no later than March 1, 2015 (so January 1, 2016 for calendar year plans), but only if the plan had a binding commitment to adopt the non-conforming plan, or had begun enrolling employees in that plan, before November 4, 2014.
While we are pleased to have you contact us by telephone, surface mail, electronic mail, or by facsimile transmission, contacting Kilpatrick Townsend & Stockton LLP or any of its attorneys does not create an attorney-client relationship. The formation of an attorney-client relationship requires consideration of multiple factors, including possible conflicts of interest. An attorney-client relationship is formed only when both you and the Firm have agreed to proceed with a defined engagement.
DO NOT CONVEY TO US ANY INFORMATION YOU REGARD AS CONFIDENTIAL UNTIL A FORMAL CLIENT-ATTORNEY RELATIONSHIP HAS BEEN ESTABLISHED.
If you do convey information, you recognize that we may review and disclose the information, and you agree that even if you regard the information as highly confidential and even if it is transmitted in a good faith effort to retain us, such a review does not preclude us from representing another client directly adverse to you, even in a matter where that information could be used against you.