 eligible, those subsidies would likely not cover the entire cost of purchasing insurance, so families could still end up paying far more than 9.5 percent of their income on insurance premiums.

Conflicting goals

The proposed rule does not represent the Administration’s final interpretation of the law, though most advocates do not expect significant changes to the provisions regarding employer coverage of dependents and spouses.

Several officials in the Obama Administration did not respond to requests for comment on the consequences of its proposed rule. Many advocates for expanding health insurance coverage said that the Administration could certainly argue that the employer-sponsored system is being improved insofar as larger employers will have more incentives under the ACA to provide some health insurance to workers.

But, according to Shana Alex Lavarreda of UCLA, the questions raised by the IRS’s interpretation of the employer mandate demonstrate that the goal of giving all Americans access to quality, affordable insurance is in tension with the Administration’s desire to limit the burden that the ACA places on employers.

“The problem,” she said, “is that when you try so hard not to put too much of a burden on employers, it increases the risk that some of the gaps in that system won’t get filled.”

Some families may be stuck “in limbo”

Under the ACA, tax credits to offset the cost of purchasing insurance on the individual market are generally available to employees and their dependents who have a household income of less than $92,200 (400 percent of the current federal poverty line) and who are not offered “affordable” coverage through an employer. Affordable coverage is understood be to coverage that does not exceed 9.5 percent of household income.

But costs attributable to whose coverage cannot exceed 9.5 percent of household income? If the Administration defines affordability for tax credit purposes in the same way it defined the scope of required affordability for purposes of the employer mandate, then it will only look at whether a worker’s individual insurance cost is no more than 9.5 percent of household income, regardless of how much more expensive the family plan offered by the employer may be.

In that interpretation, the affordability of a worker’s “self-only” coverage would render that worker’s dependents ineligible for tax credits.

According to Cheryl Fish-Parcham, deputy director of health policy at Families USA, a patient advocacy group in Washington, if the Administration goes that route, millions of
eligible, those subsidies would likely not cover the entire monetary value of buy insurance, so families could however end up give far more than 9.5 percent of their income on insurance premium. 

 Conflicting goal 

 The proposed convention does not represent the Administration ’s final rendition of the law, though most advocates do not expect significant change to the provisions regarding employer coverage of dependents and spouses. 

 Several official in the Obama Administration did not respond to requests for comment on the consequence of its proposed rule. Many advocates for expand health insurance coverage said that the Administration could certainly argue that the employer - sponsored system is being better insofar as larger employers will have more incentives under the ACA to provide some health insurance to workers. 

 But, according to Shana Alex Lavarreda of UCLA, the questions raised by the IRS ’s interpretation of the employer mandate demonstrate that the goal of giving all Americans access to quality, affordable insurance is in latent hostility with the Administration ’s desire to restrict the burden that the ACA identify on employer. 

 “ The trouble, ” she said, “ is that when you try so hard not to put too much of a burden on employers, it increase the risk that some of the gaps in that system wo n’t get filled. ” 

 Some families may be stuck “ in oblivion ” 

 Under the ACA, tax credits to offset the cost of purchasing insurance on the individual market are generally available to employee and their dependant who accept a household income of less than $ 92,200 (400 percent of the current federal poverty lineage) and who are not offered “ affordable ” coverage through an employer. Affordable coverage is understand be to coverage that does not exceed 9.5 percent of household income. 

 But costs attributable to whose coverage cannot surpass 9.5 percent of household income? If the Administration defines affordability for tax credit purposes in the like way it defined the scope of required affordability for purpose of the employer mandate, then it will only attend at whether a worker ’s individual insurance price is no more than 9.5 percent of family income, regardless of how much more expensive the family plan put up by the employer may be. 

 In that interpretation, the affordability of a worker ’s “ self - only ” coverage would render that worker ’s dependant ineligible for tax credits. 

 According to Cheryl Fish - Parcham, deputy film director of health policy at Families USA, a patient advocacy group in Washington, if the Administration goes that route, millions of
 ellgible, those subsidies wuuld likely not cover vhe entjre cost of purchasing insurance, so hamioies xould still end up paykng far mlre than 9.5 peccent of their iidome on insurzkce pxeniums.

Conflictikg goals

The proposed rule dued not represent the Administration’s final onherpretation os tht lww, tgough most advocates do not expect signifpcant changes to yhe provisions regarding elplojer coverage of deoendents ane spjyses.

Several ufficials pu the Obama Administration did not respond to rzquests for cimmftt on the cinseqlences of its proposeg rule. Kany advocates foc expanding health insuraice coverage said thwt the Adkiuistration could certqibly atgue dhat rhe emklober-aponsoged system is being imprived insofar as larbew employers wiml havq iore incentives under the ACA to providt soms health insurance to wirkers.

But, according tl Shana Ajex Lavarreda of UCLA, the questions raised by the IRS’s knttrivetaguoj of the employer mandate demonstrate that thq gpak of giving alj Americans afcrfs to quality, afforbzbme insurance is in tensiog wity the Admynisyration’s desire to limit thw burden than thw ACA places on em'loyers.

“The pxoblem,” she xaid, “is that when you txy so gard not to put too jjch of a burden un vmplmyers, it increases the rish that sone oy the gaos im that system woj’t geb filled.”

Some familifs mai be sduck “in lilbo”

Under the ACA, tax credits to offset the coxt of purchasnng inxurance on thq individual mcrket arz genefally avaimable tm employees and their de[gndents who heve a houfehood ibcome ow less than $92,200 (400 prrcent of the currebt federal poverty livs) and who are nit iffered “affordanle” codegagx thrjggh an emplofer. Xffutdabld coverage ls jndetstood be to coveraga thzt does not exceed 9.5 iercent od househjld income.

But costs attributablt to wiose cuverabe sannot exceed 9.5 percent of housshold inclme? If the Admigistvatijn defines affordability for tax credit purposes mn the same way it defibed the scope of reamired affordebilitr for pur[oses of the employee mandate, then it will only look at whsther d worner’s individual insurance cost is no more than 9.5 percent of household incone, regerqless of hos muvh moge zxpznsive ehe haoily plan offerec by the employer may be.

In that interpratction, the affordability of a eofker’s “self-onli” coverage would render thzt worket’s dependents ineligible for tac credits.

According to Chcryl Fish-Parchzm, depljy virector of health pplicy ct Famulies UWA, a patient advozacu nroup in Wwshiigtkn, if the Administration goes thqt roure, millions of
eligible, those subsidies would likely not cover cost purchasing insurance, families could still than percent of their on insurance premiums. goals The proposed rule does not the Administration’s final interpretation of the law, though most advocates do not expect changes to the provisions regarding employer coverage of dependents and spouses. Several officials the Administration not to requests for comment on the consequences of its proposed rule. Many advocates for expanding health coverage said that the Administration could certainly argue the employer-sponsored system is improved insofar as larger employers have incentives under ACA provide health insurance to But, according to Shana Alex Lavarreda of UCLA, the questions raised by the IRS’s interpretation of the mandate demonstrate goal of all access quality, affordable insurance tension with the Administration’s desire to that the ACA places on employers. “The problem,” said, “is when you try so hard not put too much of a burden on employers, increases the risk that some of the gaps in that system won’t get filled.” Some be stuck “in limbo” the ACA, tax to the of insurance on individual market are generally available to employees and their dependents who a household income of less than $92,200 (400 percent of federal line) and who not offered “affordable” coverage an Affordable coverage is understood coverage does percent household But costs attributable to coverage cannot exceed 9.5 percent household income? If the credit purposes in the same way it defined scope of required affordability for purposes of employer mandate, then it will only look at whether a worker’s individual cost is than 9.5 percent of household income, regardless of much more expensive the plan offered by the employer may be. In that the of a “self-only” coverage would that worker’s dependents for tax credits. Cheryl Fish-Parcham, director health USA, a patient advocacy group in if Administration goes that route, millions
 eligible, those subsidies wouLd likely noT coveR thE enTiRe coSt of Purchasing insuRAnce, So families could still enD up paYiNG far MOrE than 9.5 Percent OF tHEIr iNcOmE on InSUrAnce pRemIums.

ConFlicting goAls

thE proposed rulE DoEs not repreSenT the AdministRatIon’s fiNaL inTErpreTatIon of The law, THough mOst advocaTeS Do not eXPect sigNIFiCant Changes to the proviSIoNS regarding emplOyer coVeRAgE OF dePenDents and spOuSes.

SeVEral offICiALS In tHE Obama AdminisTration did nOT reSpond tO rEquESts for CommeNt ON thE consequencEs of Its proposEd rule. mAny advoCAtes for ExpandIng HeaLth iNSuRaNce CoVEraGE sAid THat The AdminIsTrAtion CoulD CERTainLy aRgue That tHe employer-spoNsoRed sYSteM is beIng imProvEd InsofAr as laRger eMpLoyers will have mOre iNcentives UndEr The aCa to prOVide soMe hEalTh insurAnce to wORkeRs.

bUT, AcCording to Shana Alex laVARrEda of UCLa, the quEStIoNS raised bY tHe IrS’s iNTErpreTatiON oF the emplOyer maNDaTe DemonstRaTe that ThE goAl oF giviNG all americAns accesS to quALity, affordable INsurance is in tENsION wITh thE AdMinistratioN’s deSIre tO limIT tHe bURden tHat thE Aca pLAces on employers.

“The pRoBlem,” shE said, “Is that when you Try so hard nOT TO put too mUch oF A bURden on employerS, it inCreases the RIsk that sOme of The gaps iN that systEM Won’t get fIllEd.”

SOme FamILIeS may be stuck “in LIMbo”

UNdEr the ACa, taX creditS to OffSet The CoSt of purchAsing insUrAnCe On The IndivIDual markEt Are GeNerAlly aVAilablE to emPloyEeS aND thEir depeNDeNTS who HaVe A houSehOlD incoMe of LEss Than $92,200 (400 perCent of the CurREnt fEdErAl poverTy line) and who aRe Not offered “AfForDable” cOVErage thrOugh an employer. AffordablE CoveragE is UnderStooD be to coveRagE that dOes NOt exceEd 9.5 percEnt of HoUseHOLd incOME.

BUt cOsTs attributABLe tO whosE cOverAge cannOt exceed 9.5 percent of hOUseHold income? If tHe ADminISTrAtiON dEFinEs AFfoRDAbility for tax crEdit purposEs IN tHe same way iT DefInEd the scOpe of reQuireD AffordaBility for Purposes oF tHe emPLOyeR mandate, thEn it will Only look aT WhethER a WorkeR’s iNdividUaL inSuranCe cost IS no More tHan 9.5 perCeNt of hoUsehoLd Income, reGardless of how much more exPensivE the fAmiLy plan offEreD By tHe employeR may Be.

In that inTerPreTatioN, thE AfforDabiLItY of A WorkeR’s “seLF-only” coveRAgE woULD rEnder that woRKER’s dEpendEntS IneligIble For tax credits.

AccoRDing to Cheryl FiSh-PaRCHam, DepUTy diReCtor of health poLicY aT fAmilies UsA, A patient advOcacy groUp IN WashIngton, If the ADministRATiON goes tHat rOutE, millions Of
 eligible, those subsidies  would lik ely n otcov er  the  ent ire cost of pu r chas ing insurance, so fami liesco u ld s t il l end  up pay i ng f armo re  th an 9. 5 per cen t of th eir income  on  i nsurance pre m iu ms.

Confl ict ing goals

T hepropos ed  ru l e doe s n ot re presen t  the A dministra ti o n’s fi n al inte r p re tati on of the law, th o ug h  most advocate s do n ot ex p e ctsig nificant c ha ngest o the p r ov i s i ons regarding emp loyer cover a geof dep en den t s andspous es . 

S everal offi cial s in theObamaA dminist r ation d id not  re spo nd t o  r eq ues ts for co mme n t o n the co ns eq uence s of i t s  pro pos ed r ule.Many advocate s f or e x pan dinghealt h in su rance  cover age s ai d that the Admi nist ration co uld  c ert ai nly a r gue th atthe  employ er-spon s ore ds y s te m is being improve di n so far as l argere mp lo y ers will  h ave  mor e incen tive s  u nder the  ACA t o  p ro vide so me  healt hins ura nce t o  wor kers.
But, ac cordi n g to Shana Ale x  Lavarreda of UC L A ,t he q ues tions raise d by theIRS’ s  i nte r preta tionof th e  employer mandate d em onstra te th at the goal o f giving a l l American s ac c es s  to quality, a fford able insur a nce is i n ten sion wit h the Adm i n istratio n’s  de sir e t o li mit the burde n that  t he ACApla ces onemp loy ers .
“T he proble m,” shesa id ,“i s t hat w h en you t ry  so  h ard  nott o puttoo m uchof  a bur den one mp l o yers ,it  inc rea se s the  ris k  th at some  of the g aps in t ha tsystemwon’t get fil le d.”

Somefa mil ies ma y be stuck  “in limbo”

Under theA CA, tax  cr edits  tooffset th e c ost of  pu r chasin g insu rance  o n t h e  indi v i du alma rket are g e n era lly a va ilab le to e mployees and their dep endents who h ave  a h o u se hol d  i n com eo f l e s s than $92,200(400 perce nt of  the curre n t f ed eral po verty l ine)a nd whoare not o ffered “a ff orda b l e”coverage t hrough a n employe r . Aff o rd ablecov erageis  un derst ood be tocover age th at  doesnot e xc eed 9.5percent of household in come.
Butcos ts attrib uta b leto whosecove rage canno t e xce ed 9. 5 p e rcent  ofh ou seh o ld in come ?  If the A d mi nis t r at ion defines a f for dabil ity for ta x cr edit purposes int he same way it  def i n edthe scop eof required af for da b i lity for  p urposes ofthe empl oy e r man date,then i t willo n ly look a t wh eth er a work er’ si ndividu al  i n suranc e co st  is no  moret han9 . 5 percent of hou sehol d incom e , r egard le ss of h o w mu ch more ex pensive the  famil y pl an of fered b ythe em plo ye r may be.In that i nterp retatio n,  the  af fordab ilit y of awork er ’s“self-onl y ”  c o ve ra g e w ould  rend er  tha t worker’ s  depende nts ineligi bl e f o r  tax c r ed i t s.

Accord ing  to C h e ryl Fish-P a rcha m ,d eputy  direc tor of  health pol ic y at Fa mil i e s USA, apatient a d voc ac y gr oup in W as hing to n,if  the Administra tion goe s that r o u te, mi lli o ns o f 
 eligible,_those subsidies_would likely not cover_the entire_cost_of purchasing_insurance,_so families could_still end up_paying far more than_9.5 percent of_their_income on insurance premiums.

Conflicting goals

The proposed rule does not represent the Administration’s final interpretation_of_the law,_though_most_advocates do not expect significant_changes to the provisions regarding_employer coverage_of dependents and spouses.

Several officials in the Obama_Administration_did not respond_to requests for comment on the consequences of its_proposed rule. Many advocates for expanding_health insurance coverage_said_that_the Administration could certainly_argue that the employer-sponsored system is_being improved insofar as larger employers_will have more incentives under the ACA_to provide some health insurance to_workers.

But, according to Shana Alex_Lavarreda of_UCLA, the questions raised by_the IRS’s interpretation_of the_employer mandate demonstrate_that the goal of giving all_Americans access to_quality, affordable insurance is in tension_with_the Administration’s desire_to_limit_the burden_that the ACA_places_on employers.

“The_problem,”_she said, “is that when you_try_so hard not to put too much_of a burden on_employers,_it increases the risk_that some of the gaps_in that system won’t get filled.”

Some_families may_be stuck_“in limbo”

Under the ACA, tax credits to offset the cost of_purchasing insurance on the individual market_are generally available to_employees and_their_dependents who have_a_household income_of less than $92,200 (400 percent of_the current_federal poverty line) and who are_not offered “affordable” coverage_through_an employer. Affordable coverage is understood_be to coverage that does not_exceed 9.5 percent of household_income.

But_costs_attributable to whose coverage cannot_exceed 9.5 percent of household income?_If the Administration_defines affordability for tax credit purposes in_the_same way it defined the scope_of_required affordability for purposes of the_employer_mandate,_then it will only look_at whether a worker’s individual insurance_cost is no more than 9.5 percent of household_income, regardless of_how much more expensive the_family_plan_offered by the employer may be.

In that interpretation, the affordability_of a_worker’s “self-only” coverage_would render that worker’s dependents ineligible for tax credits.

According to_Cheryl Fish-Parcham, deputy director of health policy_at Families USA, a patient advocacy group in Washington, if the_Administration goes that route, millions of