Health System Supports Proposed Minimum Essential Coverage Regs

May 5, 2022

Charles P. Rettig
Commissioner
Internal Revenue Service
111 Constitution Ave, NW
Washington, DC 20224

Re: IRS Reg-114339-21; Affordability of Employer Coverage for Family Members of Employees

Dear Commissioner Rettig

Trinity Health appreciates the opportunity to comment on policies set forth in IRS Reg-114339-21.

Trinity Health is one of the largest not-for-profit, Catholic health care systems in the nation. It is a family of 115,000 colleagues and nearly 26,000 physicians and clinicians caring for diverse communities across 25 states. Nationally recognized for care and experience, the Trinity Health system includes 88 hospitals, 131 continuing care locations, the second largest PACE program in the country, 125 urgent care locations and many other health and well-being services. Based in Livonia, Michigan, its annual operating revenue is $20.2 billion with $1.2 billion returned to its communities in the form of charity care and other community benefit programs.

Trinity Health has 17 Clinically Integrated Networks (CINs) that are accountable for approximately 1.5 million lives across the country through alternative payment models. Our health care system participates in 14 markets with Medicare Shared Savings Program (MSSP) Accountable Care Organizations (ACOs), which includes eleven markets partnering in one national MSSP Enhanced Track ACO, Trinity Health Integrated Care. Two of the 14 markets also participate in CPC+. In addition, we have 33 hospitals participating in the Bundled Payments for Care Improvement Advanced (BPCIA) initiative, and three hospitals in the Comprehensive Care for Joint Replacement (CJR) program. Our work — and experience in value-based contracting — also extends beyond Medicare as illustrated by our participation in 123 non-CMS APM contracts.

Driven by the belief that everyone should have access to health care coverage, Trinity Health views access to health care coverage as key to making people-centered care possible. Trinity Health supports public policies that support better health, better care, and lower costs to ensure affordable, high quality, people-centered care for all. As such, we support the revisions in the proposed IRS rule that would fix the family glitch issue by changing how affordability would be determined for an employee's family members. The proposed rule is consistent with the intent of the ACA to make affordable coverage more widely available.

It is estimated the family glitch affects about 5 million people, more than half of whom are children.¹ Fixing the family glitch will improve the affordability of health coverage for millions of people. One study estimates that under the proposed rule, about 710,000 more people would enroll in marketplace coverage with premium tax credits and 90,000 more children would be enrolled in Medicaid and the Children's Health Insurance Program when their parents sought marketplace coverage because the system will automatically check for eligibility.² Further, the Biden Administration estimates that the number of uninsured would be reduced by about 200,000.³

Trinity Health also supports the clarification in the proposed rule that employer-sponsored coverage must cover 60 percent of health care costs and provide “substantial coverage of physician services and inpatient hospital services” for employees and related individuals to qualify as minimum value coverage. This policy will help expand comprehensive coverage.

Conclusion

Trinity Health applauds the IRS for addressing the family glitch and taking steps to ensure more people can secure affordable health insurance — everyone deserve access to comprehensive health care and coverage. If you have any questions, please feel free to contact me at jennifer.nading@trinity-health.org or 202-909-0390.

Sincerely,

Jennifer Nading
Director, Medicare and Medicaid Policy and Regulatory Affairs
Trinity Health
Livonia, MI