Minimum Value Inputs

What counts toward minimum value: employer HSA contributions, qualifying HRAs and tobacco wellness credits.

The regulation lets employers count certain contributions when testing a plan for minimum value. HSA contributions, qualifying HRA amounts and tobacco-related wellness incentives count, and other wellness incentives do not.

This guide lists the conditions. The overview is the MEC vs MV guide and the test itself is in the 60 percent test. Send us your renewal and we will model your plan.

Three Inputs

What the regulation allows.

Employer HSA Contributions

Employer contributions to health savings accounts for the current plan year count toward the minimum value percentage.

Qualifying HRAs

Employer HRA contributions count only if the HRA is offered by the same employer, may reduce only covered medical cost sharing and the amount is required by the plan terms or determinable before enrollment.

Wellness Incentives

Tobacco-related incentives count as earned. Other wellness incentives do not.

Quick Reference

Counts or does not count.

Input Counts Condition
Employer HSA contribution, current plan year Yes Employer contribution.
Employer HRA contribution Yes, if conditions are met Same employer, covered medical cost sharing only, amount known before enrollment.
Tobacco-related wellness incentive Counts as earned Treated as earned.
Other wellness incentive No Does not count.
Questions We Get

Three questions about inputs.

Can an HRA that reimburses premiums count?

The regulation limits counting to HRAs that may reduce only covered medical cost sharing.

Is the HSA contribution counted for prior years?

The regulation refers to contributions for the current plan year.

Does a nonsmoker credit count?

The regulation treats tobacco-related wellness incentives as earned. Other wellness incentives do not count.

Sources

Where these figures and rules come from.

Regulation

26 CFR 1.36B-6

The minimum value standard and how contributions count are in 26 CFR 1.36B-6.

Keep Reading

Related guides.

Minimum Essential Coverage vs Minimum Value

The main guide to the two standards.

Minimum Value and Network Type

How network design interacts with the test.

The 60 Percent Test

What minimum value measures.

Penalty A vs Penalty B

How the two employer penalties differ.

ICHRA vs QSEHRA vs HRA

Choosing among the individual-coverage arrangements.

Coverage Tiers Explained

EE, ES, EC and EF in plain terms.

Let’s Get to Work

Send us your renewal.

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