Commentary: As we approach a new year, it’s time to gear up for another round of regulatory changes, particularly with respect to the Affordable Care Act. Here are six things likely to happen next year that will affect your health plan.
1. Regulations will bring more clarity to the Cadillac tax. The coming year likely will bring clarification to some unanswered questions regarding the so-called Cadillac tax — answers that will have a big impact on health and wellness at larger corporations. One answer we’ll likely get in the form of a proposed regulation is a better understanding of who is responsible for paying the tax. Currently, the ACA says that “employers,” “coverage providers,” and “person[s] that administer the benefits,” are liable for paying the tax, but the “person that administers the benefits” is never defined in the law or anywhere else. Fortunately, the IRS has indicated it will clarify this. Additionally, we are also likely to see a clearer explanation of how the cost of on-site medical clinics will be taxed under the Cadillac tax.