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Individual Responsibility for 2014 Under the Affordable Care Act (ACA) IRS Revenue Procedure 2014-46

Effective 2014, if a taxpayer is not covered under minimum essential coverage for one or more months, then, unless an exemption applies, the taxpayer is liable for the individual shared responsibility payment on his return.  The individual shared responsibility payment is the lesser of: (1) the sum of the monthly penalty amounts; or (2) the sum of the “monthly national average bronze plan premiums” for the “shared responsibility family.”

In recently published Revenue Procedure 2014-46, Sec. 3, the IRS provides that the monthly national average premium, for qualified health plans that have a bronze level of coverage and are offered through exchanges in 2014, is $204 per individual and $1,020 for a shared responsibility family with five or more members. For example, if the sum of the monthly penalty amount is $95 (or 1 percent of income) and the bronze level of coverage costs $204, the individual’s shared responsibility payment would be $95, unless the 1 percent is greater than $95.

© 2020 McDermott Will & EmeryNational Law Review, Volume IV, Number 223

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Members of our health industry practice focus their practice on one or more areas important to health industry clients, while maintaining flexibility to support other lawyers on a variety of matters.  Practice group members meet regularly to exchange ideas and share experiences that can be passed on to clients worldwide.

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