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mmpc - National Indian Health Board

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a. RE: premium subsidies and applying full APTC for purpose of Tribal sponsorship. Up to<br />

individual and IRS may not impose any requirements on how individual uses.<br />

b. When asked whether APTC could be split between a medical plan and a dental plan, Christy<br />

said she didn’t know. Doneg noted that HHS is responsible for issuing guidance re APTC for<br />

pediatric dental plans.<br />

c. Myra asked whether IRS could enter into assignment agreements whereby people who<br />

accept tribal sponsorship for payment of health insurance premiums can have any<br />

underpayment of premium tax credits paid to the sponsoring organization. IRS was not<br />

enthusiastic about the chances of this happening because IRS only uses this for limited<br />

situations and Christy thought the Tribe might not be the right kind of entity to qualify for<br />

assignment of tax refunds.<br />

d. John Stephens asked whether over or under recovery of APTC at the end of the year could<br />

be moved to the following year’s taxes. Christie responded that they couldn’t let it ride to<br />

the next year without interest. John was very effective in making the point that it will only<br />

take one tax bill for one person to end tribal sponsorship. Jim Roberts commented that<br />

Washington State was working with tribes on an aggregator model for tribal sponsorship,<br />

but it may not work due to assignment of tax credits. He asked if IRS was working with<br />

states on this. Christy said IRS isnot working with States.<br />

e.<br />

f. Follow up item: IRS is to send us the section of the tax code that applies to similar<br />

assignment so that Tribal policy wonks can determine if there is some application here that<br />

can be used for Tribal sponsorship.<br />

5. IRS Form 1040<br />

a. Christy indicated that IRS will want to consult with tribes on the question(s) put on Form<br />

1040<br />

b. We mentioned that TTAG submitted recommendations on a “single question” to ask<br />

c. It seems we should resend the old TTAG recommendations to Christy/IRS, or send a revised<br />

recommendation if preferred.<br />

6. IRS Outreach & Education<br />

a. IRS does plan to have special outreach to AI/AN, with an increase in outreach activities in<br />

2013. IRS is tied into the overall O&E campaign of HHS. IRS not in position to conduct<br />

outreach until final rules & decisions are in place.<br />

b. Voluntary tax assistance centers. There are tribal sponsors for these centers now and IRS<br />

expects to use them for ACA.<br />

i. Follow-up Item: How can Tribes become Voluntary Tax Assistance centers if they<br />

are not? Can IHS/Tribal benefits coordinators be trained to provide this assistance?<br />

Non-tribal sites will need special training about tribal benefits and sponsorship; how<br />

will this happen?<br />

c. In IRS all training is now electronic. Christie recognizes the need for face-t0-face, small<br />

group training for Tribes, but she says that the IRS needs to hear this from Tribes.<br />

d. Follow-up item: Tribes should send letter to IRS Commissioner and Sec of Treasury with cc<br />

to Christy.<br />

e. Christie recommended that we stay in touch with her about such issues as they become<br />

more clear in the coming months.<br />

f. Who do we direct our advocacy to? Normally the Deputy Secretary is responsible for Tribal<br />

issues however position is vacant (Aaron Kline left, but someone else checks in mailbox)

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