Ok, you get one guess the "purpose" of the Cadillac Tax.  One Guess.

I could give you a thousand guesses and you will never get this right.  Maybe two thousand.

NPR is a great source for news and has a broad scope of topics that play down the BIG headlines that get pounded on most broadcast news on TV and Radio.  They have segment called Marketplace.

I am writing this before the audio has posted but the host interviewed one of the PPACA Authors regarding the recent two year delay of the Cadillac Tax provision.  Let me say that my current plan is VERY close to invoking the Cadillac Tax as stated in the law.  The HSA contributions AND total Premium count to the calculation of the tax.  Yes, I have a high deductible plan ... $12,000 deductible ... thank you.  And for the record, my total plan costs are only about $1,000 less than the threshold for the tax.  Crazy.

Now, for the "purpose" of the tax, taking my current costs (and probably many of you) into account.  The expressed purpose of the Tax is to punish or try to reduce "excessive spending" in the health care insurance market.  WHAAAAT?

How in the WORLD does that work?  The IRS assesses a 40% TAX to put me (and you) is a plan worse than what I have now.  Wait, pinch me ... no hit me ... no wake me when this is over.  Never have I had a nightmare worse than this.  But, in a government where Tax Cuts are called "spending" and every budget line item gets an annual increase of 10% or it is called a cut, I guess that makes sense.  I just want to know where the line is forming that allows my business to increase prices 10% every year, or I get to scream foul!

Whew!  I feel better.

We need an HONEST discussion about how this works.  What is best.  Not just to grow government but to reduce real costs for care and insurance to protect our assets.

"It has been said the smart people often disagree but only one is right."

Like most people in our industry today, I get a lot of e-mail linked to blog posts and many are focused on the current "hot topic" ... 1095 Filing.

Here are two answers written by two law firms to the same question about how to report COBRA events on the 1095-C.  What am I missing?

This one can be found at this LINK
Q5:  How is COBRA coverage reported?
​A5:  Under recent IRS guidance, for the first full month of COBRA coverage, Code 1H applies (No Offer of Coverage) in Line 14 and Code 2A (Employee not employed during the month) applies in Line 16.  If the plan is self-insured, the same codes apply for the period of COBRA coverage, however, for the applicable months of coverage, Part III is completed showing the months the individuals are covered under the plan – either as employees or COBRA beneficiaries.

This one can be found at this LINK
Now let’s assume that our full-time employee, who previously enrolled in coverage, transfers to a part-time position on July 1, and remains a part-time employee for the balance of the year. The employee would qualify for an offer of COBRA coverage. For January through June, the reporting treatment would be the same as the previous example involving termination. For the balance of the year, Line 14 would continue to be coded 1E (an offer of COBRA coverage to a former employee is ignored, but an offer of COBRA coverage to an ongoing employee counts as an offer of coverage). On Line 15, the employer would report the self-only COBRA coverage rate. If the employee accepted the COBRA coverage, Line 16 would be coded 2C; if declined, Line 16 would be coded 2B (Employee not a full-time employee).


Yes, the second example is for an employee that moves to part-time but they lost eligibility and no offer can be made.  We could fill volumes with the fuzzy nature of these reporting requirements. There are dramatic differences between what the IRS said in July and September.  Our plan remains to process early and file the IRS versions a week or so before the deadlines.  That gives us the best chance of complying with the last version of the interpretations of the codes and filing requirements.

Thank you to all those that have entrusted these filings to our care!