Notice 2015-16 (May 15, 2015)

Health Care

From the Church Alliance to the Internal Revenue Service (IRS), in response to Notice 2015-16, which solicited comments in preparation for proposed regulations to be issued concerning the “Cadillac Tax” on high cost employer-sponsored health coverage. The Affordable Care Act included a provision imposing an excise tax on such coverage. The letter urges the IRS to consider the unique difficulties for denominational health plans in determining the cost of coverage. The letter requests relief from the excise tax, including transition relief and relief with respect to the cost of coverage provided under a self-insured group health plan that is not subject to federal continuation coverage requirements, flexibility in the application of the excise tax, and adjustments to the applicable dollar limits for denominational health plans and church employers.