Coalition on Benefits

The Latest

National Coalition on Benefits Letter to Senate Leadership Regarding Health Care Reform Legislation

May 17, 2017

May 17, 2017 Submitted via email The Honorable Mitch McConnell Majority Leader United States Senate Washington, DC 20510 The Honorable Chuck Schumer Minority Leader United States Senate Washington, DC 20510   Dear Leaders: As the Senate works on health care reform legislation, the National Coalition on Benefits (NCB) urges you to carefully evaluate the effect it may have on employees and their families. Your work on this legislation should ensure that any changes do not impede the ability of employers to offer coverage and for employees to afford this coverage. The NCB is comprised of industry trade associations representing large and small businesses, as well as employers with operations and employees in all 50 states. The Coalition has been a long-time supporter of ensuring all Americans have access to affordable health insurance coverage. In particular, we support legislation preserving the ability of employers to offer uniform coverage across all 50 states, as provided under current pre-emption provisions in the ERISA statute. Health care reform must recognize the important role employers play in providing quality, affordable health benefits to more than 177 million Americans. As health care reform moves forward, federal policies should leverage and encourage the innovation of employer-sponsored health care benefits and support the flexibility necessary to enable larger employers to continue to make these innovations. Key to this is to ensure that increased state flexibility does not erode ERISA preemption, which enables multistate employers to seek lower-cost, nationwide pricing for health care services, and drive innovation in benefit and plan design that fosters new health care cost controls and improved the quality of care. NCB looks forward to working with you and the entire Senate as you consider proposals addressing how best to achieve our shared goals and objectives for the U.S. health care system: lower costs, improved access, greater transparency and higher quality. Sincerely,                                              The National Coalition on Benefits   CC: Members of the United States Senate


National Coalition on Benefits Employer Reporting Relief Letter to Trump Administration

January 31, 2017

Andrew Bremberg Assistant to the President and Director of the Domestic Policy Council The White House 1600 Pennsylvania Avenue NW Washington, DC 20500 Re: Employer Reporting Under the Affordable Care Act Dear Mr. Bremberg: Congratulations and thank you for serving our nation as part of the new Trump Administration. The National Coalition on Benefits (“Coalition”) looks forward to working with you. The Coalition is comprised of industry trade associations representing large and small businesses, as well as employers with operations and employees in all 50 states. The Coalition has been a long-time supporter of ensuring all Americans have access to affordable health insurance coverage. More than 177 million Americans currently enjoy employer-sponsored health coverage, and we urge you to protect this important benefit as you work to repeal and replace the Patient Protection and Affordable Care Act (“ACA”). We greatly appreciate the flexible approach outlined in President Trump’s Executive Order, issued on January 20, 2017, which instructed federal agencies to minimize the economic burdens of the ACA for a range of stakeholders, including purchasers of health insurance. This would include employers who provide health benefits to employees using insurance and self-insured arrangements. This letter focuses exclusively on the issue of the employer mandate and the accompanying employer reporting requirements, given the immediate and burdensome deadlines of March 2, 2017, and March 31, 2017. We also look forward to working with the Trump Administration to ensure the ability of employers to offer uniform coverage across all 50 states is maintained and strengthened and the tax-treatment of health care is beneficial for employees and employers alike. Under the ACA, employers over a certain size face an excise tax if they do not offer certain qualifying coverage to employees who work an average of 30 or more hours per week (the “employer mandate”). They must also collect copious amounts of information and complete forms that must be provided to their employees and filed with the Internal Revenue Service (IRS) on an annual basis. Under the law, employers that do not offer such qualifying coverage or are unable to file or furnish the IRS forms run the risk of incurring significant penalties. The stringent requirements imposed on employers by the associated reporting obligations have been, and will continue to be, very difficult and costly for employers. We urge you to act in accordance with the Executive Order to “exercise all discretion and authority available to waive, defer, grant exemptions from, or delay the implementation of any requirement of the Act” by taking immediate steps to ease the burdens imposed on employers by the ACA’s mandatory reporting obligations. We conclude by asking that you use the full authority vested in the Executive Branch to relieve employers of the burdens imposed on them by the ACA. We look forward to working with you to continue providing working Americans and their families with access to quality employer-sponsored health coverage, while easing the economic and regulatory burdens imposed on employers by the ACA. Thank you for considering our views on this matter. If you have any questions or would like to discuss these comments further, please contact us. Sincerely, The National Coalition on Benefits CC: Acting Secretary Szubin, Department of the Treasury Commissioner Koskinen, Internal Revenue Service Individual Members of Congress


Secretary Clinton, Donald Trump: Protect Employee Health Benefits

August 09, 2016

Employers both large and small oppose taxes or limitations on employee health benefits. In an open letter to Secretary Hillary Rodham Clinton and Donald J. Trump, America's employers said: "[O]ver 175 million American are enrolled in employer-sponsored coverage, and these employees report that their health care benefits are 'extremely' or 'very' important. ... "[T]he health care law's 40 percent tax on health benefits must be repealed. ... "Employers are adopting new strategies that are improving the delivery of health care, driving... reforms, helping employees ... and their families ...." Click here to view the full letter. Protect the health coverage of more than 175 million Americans.


National Coalition on Benefits Letter to Hillary Clinton and Donald Trump

August 08, 2016

Secretary Hillary Rodham Clinton Hillary for America One Pierrepont Plaza Brooklyn, New York 11201 Mr. Donald J. Trump Trump Tower 725 5th Avenue New York, New York 10022 Dear Secretary Clinton and Mr. Trump: Congratulations on securing your party’s nomination as a candidate for president. On behalf of the National Coalition on Benefits (NCB), we are seeking your  support of policies that we believe will strengthen employer-sponsored health care coverage. NCB is comprised of industry trade associations representing large and small  employers in all 50 states. Employers are one of the nation’s largest payers of  health care services and we recognize our nation’s challenges in controlling health  care spending. Employers work hard to offer health care benefits that include  wellness and plan design innovations, which deliver quality, affordable health  care for our employees. As you develop and discuss your health care reform agenda, please consider  these three important policy pillars for strengthening employer-sponsored  coverage: First, over 175 million Americans are enrolled in employer-sponsored  coverage, and these employees report that their health care benefits are  “extremely” or “very” important. Continuing to offer these benefits is  possible because of the federal Employee Retirement Income Security Act (ERISA) and its role in enabling uniform benefits to be offered to employees  no matter where they live, work or receive medical care. Second, the health care law’s 40 percent tax on health benefits must be  repealed. NCB does not support the so-called Cadillac Tax or other changes  to the tax treatment of employer-sponsored health benefits that could  adversely impact our employees and the employer-based health system. In  particular, we are concerned that these tax changes will be especially hard  for older workers, employees and family members with chronic illnesses or  employees who live in high-cost areas of the country. Finally, innovations in employer-sponsored coverage are helping to reduce  health care spending. Employers are adopting new strategies that are  improving the delivery of health care, driving value?based payment  reforms, helping employees maintain their health and empowering employees and their families with more tools to help them avoid and  manage chronic illnesses. In closing, NCB looks forward to working with you to support employer-sponsored  health care coverage and innovations to lower health care costs for both  employers and employees and the communities in which they live


America’s Employers: Health Care Modernization Must Protect Employer-Sponsored Benefits

June 22, 2016

Washington – The National Coalition on Benefits (NCB) applauds the House Republican Task Force on Health Care Reform proposal’s recognition of the important role employers play in providing quality, affordable health benefits to more than 175 million Americans. We also urge Congress to carefully review the proposal and evaluate the effect on employees and their families in proposing changes to the tax treatment of employer-sponsored health benefits. This review should ensure that such changes do not impede the ability of employers to offer coverage and for employees to afford this coverage. NCB looks forward to participating in the forthcoming conversation about how best to achieve our shared goals and objectives for the U.S. health care system: lower costs, improved access, greater transparency and higher quality. Protect health benefits for more than 175 million Americans.  


America’s Employers Welcome Congressional Hearing on Health Care Innovations

April 14, 2016

Washington – The National Coalition on Benefits applauds House Education and Workforce Committee Chairman John Kline (R-MN) and Subcommittee on Health, Employment, Labor and Pensions Chairman Phil Roe (R-TN) for showcasing the highly successful innovations that private-sector employers have developed to improve the quality and affordability of health care in the United States. Examples include: Workplace wellness programs Private exchanges On-site medical clinics Hospital quality and safety standards Innovative delivery system models Approximately 175 million Americans have health, retirement and other valuable benefits provided by their employer under a uniform national framework established by the Employee Retirement Income Security Act (ERISA). America’s employers believe that as Congress considers changes to the U.S. health care delivery system, care should be taken to preserve ERISA – the framework for the health care coverage on which millions of Americans depend. Protect health benefits for more than 175 million Americans.


Employers Express Concerns Regarding Proposals to Change Tax Treatment of Job-Based Health Benefits

April 14, 2016

Washington – Mallory Micetich, a spokesperson for the National Coalition on Benefits, today issued the following statement in advance of the House Ways and Means Committee hearing on “The Tax Treatment of Health Care”: “Private sector employers urge Members of the House Ways & Means Committee to avoid changes to the tax treatment of employer-sponsored health benefits that adversely impact employers and employees. “Such changes impede the ability of employers to offer coverage and for employees to afford it.”   Protect the health coverage of more than 175 million Americans.


Letter to Chairmen Price, Kline, Upton and Brady

March 18, 2016

Dear Chairmen Price, Kline, Upton and Brady: The National Coalition on Benefits (NCB) is dedicated to preserving the benefits of millions of Americans who receive health insurance through employers. The coalition is comprised of major employer trade associations, representing large and small employers. NCB also includes many large employers with employees and retirees in all 50 states. We are writing to urge your support for strengthening the employer-sponsored health care system. We are united around one central principle: we support employer-sponsored coverage in America and the federal Employee Retirement Income Security Act (ERISA) law that protects and enables coverage. Employers want to continue offering coverage for many reasons; not only to retain employees, but also to provide them with the right tools to remain healthy and productive. Surveys have shown that employees, retirees and dependents favorably view employer-sponsored coverage. At the same time, we welcome the discussion in the Task Forces on ways to improve the health of our communities, and we believe that employers remain a key to that improvement. As you evaluate health care reform alternatives, we want to emphasize three important messages on employer-sponsored coverage: First, over 175 million Americans are enrolled in employer-sponsored coverage; a growing number according to a recently-released report from the Employee Benefit Research Institute. Moreover, according to a Kaiser Family Foundation Survey, 88 percent of workers report that health benefits are “extremely” or “very” important. We urge you to protect ERISA and its role in fostering employer-sponsored coverage. As you seek to improve the health system, we ask that you work with us to promote simplicity and flexibility in the offering of employer-sponsored health benefits. We are eager to have a discussion regarding how employer plans can further the goals of transparency and portability. Second, we believe the ACA’s 40 percent tax on health benefits must be repealed. NCB does not support such modification to the tax treatment of employer-sponsored coverage. There is no consistent evidence that taxing health benefits will result in savings to the health system. Instead, changes in the tax treatment of employersponsored benefits that adversely affect employers and employees will have a widespread impact and particularly be felt by individuals whose employers have an older workforce, or a workforce with employees and family members with chronic illnesses, or a workforce with employees who live in high-cost areas of the country. Further, the political challenge of enacting health care reforms will not be eased by creating a de facto tax increase for many employees. Finally, we believe that greater innovations in employer-sponsored coverage may help reduce health care spending. Employers are adopting new strategies to improve the delivery of health care and are empowering employees and their families with more tools to help them avoid preventable chronic illnesses. Some are providing employees with on-site – or access to mobile or nearby – clinics to receive screening and routine services. Others are driving greater performance in provider networks. These are all innovations that can improve each and every community where employees live. We support your efforts to strengthen the individual health coverage system, but not at the expense of the employer-sponsored system that is highly valued by the majority of Americans who receive their health coverage through employers today and is a critical source of innovation necessary to improve the health of our communities. In closing, NCB looks forward to working with you and your colleagues to continue supporting and encouraging innovations in employer-provided health care coverage and to lower health care costs for both employers and employees and the communities in which they live. Sincerely, National Coalition on Benefits   c.c.: The Honorable Paul Ryan The Honorable Kevin McCarthy The Honorable Steve Scalise


Statement of Janet Boyd - Chairman, National Coalition on Benefits Committee on Education and the Workforce

March 02, 2016

Good morning Chairman Roe and Chairman Kline, I am Janet Boyd, Director of Government Relations and Legislative Counsel for The Dow Chemical Company, and am speaking today on behalf of the National Coalition on Benefits (NCB). The NCB is a coalition of businesses and employer associations that are working together to support preserving employer-sponsored coverage. For decades, more Americans have relied upon their employers for health coverage for themselves and their families. Employers have embraced this important role as a way to recruit and retain workforces; there is a business imperative for our engagement. Employer-sponsored coverage should be retained. We appreciate the opportunity to provide you information on what is working, what is not working and how we can assist with your efforts to examine the future of employer health care coverage. There are over 175 million Americans who receive health care coverage through their employer – and with a total U.S. population of 316 million – that means more than half of all Americans get coverage at work. Many companies in America work hard to ensure quality and affordable coverage for their workers. Today, I would like to stress three key points: The foundation of employer-sponsored coverage is the Employee Retirement Security Act (ERISA). This law permits multi-state employers to offer the same coverage to all employees no matter what state they live in and to adopt consistent rules governing the administration of the benefit to all employees. ERISA requirements apply to all employers that offer benefits. We urge you to protect and preserve ERISA and to find ways to promote greater simplicity and predictability in the implementation of those rules. Simplicity and predictability will permit employers to continue offering coverage, lower costs and provide greater health and financial security for millions of Americans. Any alternative to the Affordable Care Act should preserve the favorable tax treatment of employer-sponsored coverage. Taxes and burdensome regulations only increase costs and limit employers from innovating in benefit design and ensuring affordable coverage. One of the challenges with the ACA are the unnecessary taxes in the law, with a specific emphasis today to support the repeal of the 40 percent tax on health care benefits. This tax will not reduce health care spending or “bend the health care cost curve.” We urge you to support policies that foster greater innovations in employer-sponsored coverage. Employer innovations can help create a more cost effective health care system. Companies are driven to keep the overall cost of programs down – both for themselves and their employees. Employers have designed innovative programs, such as wellness programs, on-site clinics, pooled purchasing, telemedicine and mobile treatment and diagnostic programs to make it easier for employees to access good, quality care. Employers are enthusiastic about these efforts – and we believe these are tools that can be used or help to sustain other programs, such as Medicare and Medicaid. Let me provide more specifics on each issue: ERISA IS THE FOUNDATION ERISA is the foundation of employer-sponsored coverage and we encourage you to strengthen the protections under ERISA. ERISA permits employers to offer uniform employer-sponsored coverage nationwide. This leads to better benefit design, reduction in administrative costs through economies of scale and increased purchasing power. Employers demand quality and efficiency from the health care providers with whom they contract, applying best practices across all markets. Every employer is different. The cost of employer-sponsored coverage has been estimated at $6,250 for single coverage and $17,500 for family coverage.[1] However, each employer-group plan has different characteristics of those they cover – older, younger, sicker, retirees, families. Employer plans need to vary, depending on their specific workforce demographics. Three-fifths of employment-based health insurance is offered through self-insured plans and purely governed under ERISA. We urge you to support the employer-based system and ERISA protections that could impact the value of these benefits for American workers and their families. Most importantly, 88 percent of workers report that employment-based health insurance is extremely or very important, far more than for any other workplace benefit.[2] We encourage you to retain employer-sponsored coverage in your health care plan.  CHANGES TO THE AFFORDABLE CARE ACT (ACA) Requirements in the ACA that merely add costs to employer-sponsored coverage and limit the innovations that employers may offer should be reconsidered. In particular, the NCB is united in its strong opposition to the 40 percent tax on employee benefits. According to CBO, the cost of coverage for employees and their families includes: ...The costs of health care generally…determined by the quantity and kind of services that people use and the prices that are paid for those services. Those components, in turn, are a function of the population’s health and need for services, the state of medical technology and treatment options, physicians’ patterns of practice, and various other considerations…A group of enrollees that is older or sick will tend to use more health care and thus will generate high premiums, if other factors are held equal…[3] Any changes to the tax treatment of employee health benefits will only impact the direct costs of certain plan benefits and not the cost of care. It will impact those employers who employ older workers, who employ workers who may have higher rates of illness and disability or impact those employers who have employees in higher cost states. While some believe taxing these benefits will result in employers buying lower cost coverage, it will not. Employers may not be able to find lower cost coverage – even though employers want their employees to have health coverage. As a coalition of leading employer trade associations and employers providing health benefits, there are other ways to bend the cost curve. We want to work with you on finding ways to deliver and pay for services that are more affordable. However, adding taxes or complex regulatory requirements on employer-sponsored coverage will only drive up the costs of care and may force employers to drop innovative benefit offerings in the future. INNOVATIONS IN HEALTH CARE Employers are adopting strategies to improve the health benefit offerings to their employees and families. At The Dow Chemical Company, for example, we view health spending as an investment for our employees and the value of our company. We have a broad approach to improve patient outcomes, enhance the quality and effectiveness of care, reduce waste and provide better value for every dollar spent. Other NCB companies are doing similar activities. According to the 2015 Health Care Survey, many employers are adopting innovative strategies to improve the value of the health care benefits and reduce increasing costs. Some of the activities cited include: increase employees’ awareness of and decision making related to health issues; increase employee use of tools and information on provider price and quality; lower health care reform compliance and risk; improve health improvement program compliance; increase the use of integrated delivery systems and high performing provider networks; and other innovative ways to improve the cost and value of employer-sponsored health coverage.[4] These types of innovations only improve each and every marketplace where we have employees. More can and will be done if Congress reaffirms its support for employer sponsored coverage and permits employers to have flexibility and continuity in offering valued health coverage to their employees and families. Thank you for the opportunity to discuss the value of ERISA and employer sponsored coverage.   [1] Gary Claxton and others, 2015 Employer Health Benefits Survey (Kaiser Family Foundation and Health Research and Education Trust, September 2015), http;// [2] Views on the Value of Voluntary Workplace Benefits: Findings from the 2015 Health and Voluntary Workplace Benefits Survey, Employee Benefit Research Institute, November 2015, Vol. 36, No. 11. [3] CBO Report: Private Health Insurance Premiums and Federal Policy, Average Premiums for Employment-Based Plans, February 2016 [4] Aon Hewitt, 2015 Health Care Survey Results.


Employers Continue to Support Repeal of the 40 Percent Tax on Health Care Benefits

February 09, 2016

Washington – Mallory Micetich, a spokesperson for the National Coalition on Benefits, today issued the following statement regarding President Obama’s proposal to change the scope of the 40 percent tax on health benefits mandated by the Affordable Care Act. “America’s employers, both large and small, continue to support a full repeal of the 40 percent tax on health benefits. Absent repeal, the 40 percent tax will slow private sector health care innovation and erode the value of the employer-sponsored health care benefits upon which more than 175 million Americans currently rely. “The 40 percent tax undercuts the ability of employers to design plans to fit their employees’ needs. As a result, proposals to ‘fix’ the tax, such as the one included in President Obama’s budget proposal will not solve the underlying problems and unintended consequences the tax creates for employees. “The National Coalition on Benefits strongly urges Congress to repeal the tax this year.”