Aimed Alliance Releases New Fact Sheet on IRS’s 2004 Notice and Copay Accumulator Reform


Aimed Alliance has published a new fact sheet titled IRS’s 2004 Notice Should Not Prevent Copay Accumulator ReformThe fact sheet reviews how copay accumulator programs operate and the recent confusion surrounding the Internal Revenue Service (IRS) interpretation of its 2004 notice. The 2004 IRS Notice stated that individuals who have health savings account (HSA) for high deductible health plans (HDHP) can use discount cards so long as the discount cards do not count towards the plan’s deductible or annual out-of-pocket limit. As a result of the IRS 2004 Notice, the Department of Health and Human Services and the Department of the Treasury have revoked protections that would have prohibited copay accumulator programs which shift additional costs to patients. Our fact sheet explains that this notice should not act as a bar to copay accumulator reform because the IRS notice is not legally binding; the preclusion of “discount cards” should not also be considered a preclusion of copay assistance; the notice is inconsistent with the HSA statute; and this interpretation is overly broad and harmful to patients. The fact sheet can be found here.  


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