On November 4, 2014, the Internal Revenue Service (IRS) released guidance (Notice 2014-69) clarifying that certain group health plans that do not provide for hospitalization services or physician services or both will fail to satisfy the minimum value requirements for purposes of the employer mandate of the Affordable Care Act (ACA). This means employers that do not qualify for transition relief and offer such health plans will not be considered to meet the requirements of the employer mandate and may be subject to a penalty.
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