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Clarity Comes To ACA's 'Minimum Essential Coverage'

December 12, 2014, Law360

Covington's Caroline Brown and Phil Peisch have authored this article on the Affordable Care Act's commercial essential health benefits rules, issued by the Centers for Medicare & Medicaid Services, which has resulted in a complex benefit design process for certain commercial plans and for Medicaid alternative benefit plans:

"In the last few weeks, the Internal Revenue Services finalized rules and published subregulatory guidance about the definition of government-sponsored minimum essential coverage and about claiming a hardship exemption from the Affordable Care Act’s individual mandate: IRS, Final Rulemaking, Minimum Essential Coverage and Other Rules Regarding the Shared Responsibility Payment for 

Individuals, 79 Fed. Reg. 70464 (Nov. 26, 2014); IRS Notice 2014-76 (Nov. 21, 2014); and IRS Notice 2014-71 (Nov. 7, 2014)."

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