It was just over a year ago that the Wall Street Journal published an article entitled, “Employers Eye Bare-Bones Health Plans Under New Law,” which highlighted a compliance strategy to minimize employer exposure for assessable payments under the employer shared responsibility provisions of the Affordable Care Act using what has now come to be called either a “skinny” plan or an “MEC” plan.

Over the last year, skinny plans have gained some grudging acceptance. And a consensus appears to have emerged to the effect that, while a skinny plan might be limited to preventative services only, the skinny plans appearing in the marketplace generally include a handful of other features, e.g., wellness programs and perhaps an elective (i.e., “non-coordinated”) hospital or fixed indemnity feature.

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