'Minimum Value' (MV) is an ACA technical term referring to a health plan that pays at least 60% of total allowed costs for covered benefits — the actuarial threshold for the Bronze metal tier. For Florida ALE employers, offering a Minimum Value Plan is the second pillar of avoiding the §4980H(b) penalty (the first is offering 'affordable' coverage). All ACA-compliant metal-tier plans (Bronze, Silver, Gold, Platinum) satisfy the MV standard automatically. Bare-bones MEC plans typically do NOT satisfy MV. This guide explains the test, the HHS Minimum Value Calculator, and how MV interacts with affordability for compliance.
A plan provides 'minimum value' if its plan share (employer + carrier portion) of total allowed costs for covered services equals at least 60% of the total cost. The other 40% is the employee's expected share (deductibles, copays, coinsurance, premiums up to OOP max).
| Metal Tier | Actuarial Value | MV Compliant? |
|---|---|---|
| Bronze | 60% | Yes (right at threshold) |
| Silver | 70% | Yes |
| Gold | 80% | Yes |
| Platinum | 90% | Yes |
| MEC plan (preventive only) | ~10-30% | No |
| Catastrophic plan (under-30 marketplace) | ~58% | No |
Beyond the 60% AV calculation, MV plans must also provide 'substantial coverage' of in-patient hospital services and physician services. This rule was added by IRS Notice 2014-69 to address the 'skinny plan' loophole where some plans achieved 60% AV through cost-sharing structures while excluding hospital coverage entirely.
HHS publishes a free Minimum Value Calculator that determines whether a specific plan design satisfies MV. Inputs include:
Carriers run their plans through this calculator and certify MV status. Brokers can access the calculator and demonstrate MV for any plan you're considering.
For ALEs to avoid §4980H(b) penalty, the offer must be both:
Both conditions must be satisfied. Offering only an unaffordable MV plan = §4980H(b) penalty exposure for any EE who gets APTC.
| Plan Setup | MV? | Recommended Use |
|---|---|---|
| Bronze HSA-qualified plan with $5K deductible | Yes (60%) | Cost-conscious workforce; pair with HSA |
| Silver PPO with $2K deductible | Yes (70%) | Most common Florida small group default |
| Gold HMO with $500 deductible | Yes (80%) | Higher-touch coverage for older workforce |
| MEC + Bronze MVP combo | MEC: No / Bronze: Yes | Cost minimization with employee choice |
Yes — if the plan's actuarial value is 60% or more (per the HHS calculator), it satisfies MV regardless of deductible amount. HSA-qualified Bronze plans with $5,000+ deductibles routinely pass MV because the cost-sharing structure averages out to 60%.
Only the MV half. You also need to satisfy affordability — employee share of employee-only premium ≤ 8.39% of household income (2026). MV without affordability = §4980H(b) penalty exposure.
Most level-funded plans are designed to satisfy MV (60%+ AV), but verify each plan with the carrier's certification. Some level-funded plans are designed to be 'minimum compliance' and may sit right at 60%.
A licensed Florida broker can verify MV status for any plan you're considering.
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