On Nov. 4, 2014, the IRS issued Notice 2014-69 to clarify that plans that do not provide in-patient hospitalization or physician services (referred to as Non-Hospital/Non-Physician Services Plans) do not provide minimum value. Accordingly, a Non-Hospital/Non-Physician Services Plan should not be adopted for the 2015 plan year. However, transition relief is available for some plans. This Health Care Reform Bulletin provides an overview of Notice 2014-69.

IRS Closes Minimum Value Loophole for Low-Cost Employer Plans