Comment Letters


  • ECFC Comment Letter on IRS Notice 2015-87

    • This letter was submitted on behalf of the Employers Council on Flexible Compensation (“ECFC”) with respect to IRS Notice 2015-87 (the”Notice).

  • ECFC Comment Letter on U.S. Senate’s Passage of Bill That Would Repeal Cadillac Tax

    • ECFC legislative director Bill Sweetnam commented that the Senate’s vote in favor of repeal speaks very loudly. The vast majority recognizes that the Cadillac tax will have serious consequences for American employees and their ability to save and plan for their families’ healthcare needs. Now, it’s a matter of finding the right path legislatively to make sure the Cadillac tax either gets repealed in full, or at least, in the interim, revised to exempt employee contributions to health benefits accounts like Flexible Spending Accounts and Health Savings Accounts from the tax calculation.

  • ECFC Comment Letter on IRS Notice 2015-52, Regarding the Excise Tax

    • This letter details members’ concerns about the impact of the excise tax on consumer-directed benefit arrangements, persons liable for the tax, and allocation of contributions to FSAs, HRAs and HSAs.
  • ECFC Comment Letters on American Worker Health Care Tax Relief Act of 2015

    • ECFC letters of support to Senators Brown and Sanders for introduction of the American Worker Health Care Tax Relief Act of 2015, a bill that would repeal the excise tax on high cost employer-sponsored health coverage.

  • ECFC Comment Letters on Middle Class Health Benefits Tax Repeal Act of 2015

    • ECFC letters of support to Senators Heller and Heinrich for introduction of the Middle Class Health Benefits Tax Repeal Act of 2015, a bill that would repeal the excise tax on high cost employer-sponsored health coverage.

  • ECFC Comment Letter Showing Support for Restoring Access to Medication Act (H.R.1270)

    • Letter to Paul Ryan, Chair of the Committee on Ways and Means, expresses strong support for bill that would restore consumers’ ability to purchase OTC medicine with pre-tax dollars without first obtaining a physician’s prescription.

  • ECFC Comment Letters on Small Business Healthcare Relief Act

    • ECFC comment Letters to Senators Grassley and Heitkamp and Representatives Thompson and Boustany on the introduction of the Small Business Healthcare Relief Act (S.1697) and (H.R.2911)
  • ECFC Comment Letter on Consumer Financial Protection Bureau-March 23, 2015

    • ECFC applauds the CFPB for its recognition that certain employer sponsored benefit arrangements are not prepaid accounts in the first instance, and requests that CFPB extend the exception to certain other employer sponsored benefit arrangements.

  • ECFC Comment Letter on Amendments to Excepted Benefits 2013-30553 – February 21, 2014

  • ECFC Comment Letter on Proposed Rule on ACA, HHS Notice of Benefit and Payment Parameters for 2014

  • ECFC Comment Letter on HHS Released Proposed Rule on standards related to health benefits, actuarial value, and accreditation – December 21, 2012

  • ECFC Comment Letter on Proposed Rule on ACA, HHS Notice of Benefit and Payment Parameters for 2014

  • ECFC Comment Letter to HHS, Treasury, and Labor Requesting guidance on a new excepted benefit category under HIPAA for HRAs – October 2, 2012

    • The letter lays out specific recommendations for the Departments to consider when crafting and issuing guidance on this matter. ECFC encouraged the Departments to contact us to discuss this issue further.

  • ECFC Comment Letter on Internal Revenue Service (IRS) Notice 2012-38 regarding qualification of debit card under Rev. Rul. 2006-57 – August 24, 2014

  • ECFC Comment Letter on the SBC Rules – August 8, 2012

  • ECFC Comment Letter on Internal Revenue Service (IRS) Notice 2012-40, Comments on modification to flexible spending account (Health FSA) use-or-lose it rule – August 7, 2012

  • ECFC Letter to Chairman Camp on HR 436, the Health Care Cost Reduction Act of 2012 – June 7, 2012

  • ECFC Letter on HR 2526, Healthcare Reform - June 18 2009