First Focus on Children submitted the following comment to Internal Revenue Service to express our support for the proposed regulations to fix the so-called “family glitch.”
Excerpt from the Comment:
By modifying the “affordability rule” to include related individuals, more children will have access to affordable health insurance. We agree with the intent of the new proposed regulations which clarify that an eligible employer-sponsored plan is affordable for related individuals if the portion of the annual premium the employee must pay for family coverage, that is, the employee’s required contribution, does not exceed 9.5 percent of household income. Until now, children and other family members of employees were either going without health insurance coverage or paying hundreds of dollars a month for premiums in the private insurance market because they were not eligible for premium tax credits under the ACA. First Focus on Children also agrees with the interpretation that the lack of a separate minimum value rule for related individuals is inconsistent with the overall goal of the ACA in providing comprehensive, affordable health coverage, as well as the goal of improving access to quality and affordable health care. We support the new proposed regulations that an eligible employer-sponsored plan satisfies the minimum value requirement only if the plan’s share of the total allowed costs of benefits provided to related individuals is at least 60 percent, similar to the existing rule for employees. We also support the proposed regulations that require eligible employer-sponsored plans to include substantial coverage of inpatient hospital services and physician services.