ACA Affordability Percentage Reduced to 9.78% for 2020

For the second time in the ACA’s history, the required contribution percentage used to determine whether employer-sponsored health coverage is “affordable” has been reduced.

For plan years beginning in 2020, the Internal Revenue Service has announced that coverage will generally be considered affordable if the employee's required contribution for the lowest cost self-only health plan offered is 9.78% or less of his or her household income for the taxable year. This is a decrease from the 9.86% affordability threshold applicable for plan years beginning in 2019.

Because employers are unlikely to know an employee's actual household income, they may use a number of IRS provided safe harbors to determine affordability of their plan offerings. Adjustments to the affordability percentage are important as failure to get the safe harbor calculation right can lead to costly penalties.

This E-Alert is of interest to applicable large employers - generally those with 50 or more full-time employees (including full-time equivalent employees). Under the ACA’s employer shared responsibility ("Pay or Play") provisions, large employers may be subject to a penalty if they do not offer affordable coverage that provides minimum value to their full-time employees and their dependent child(ren).

As always, please do not hesitate to reach out with any questions or concerns.

Disclaimer: The information contained in this message is for general informational purposes only and does not constitute legal advice.