[Congressional Record Volume 161, Number 175 (Thursday, December 3, 2015)]
[Senate]
[Pages S8385-S8387]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]

  SA 2892. Mrs. SHAHEEN (for herself, Mr. Wyden, Mrs. Murray, and Ms. 
Stabenow) submitted an amendment intended to be proposed to amendment 
SA 2874 proposed by Mr. McConnell to the bill H.R. 3762, to provide for 
reconciliation pursuant to section 2002 of the concurrent resolution on 
the budget for fiscal year 2016; as follows:

       At the appropriate place, insert the following:

     SEC. __. MENTAL HEALTH AND SUBSTANCE USE PREVENTION AND 
                   TREATMENT.

       (a) Applicability of Mental Health Parity and Addiction 
     Equity.--Section 1311(j) of the Patient Protection and 
     Affordable Care Act (42 U.S.C. 18031(j)) is amended to read 
     as follows:
       ``(j) Applicability of Mental Health Parity and Addiction 
     Equity.--
       ``(1) In general.--Section 2726 of the Public Health 
     Service Act shall apply to qualified health plans in the same 
     manner and to the same extent as such section applies to 
     health insurance issuers and group health plans.
       ``(2) Transparency of claims denial.--
       ``(A) In general.--The Secretary shall require an Exchange 
     to collect data on the percentage of health insurance claims 
     denied for mental health benefits and the percentage of such 
     claims denied for substance use disorder benefits. Such 
     Exchange shall maintain an Internet website for the 
     publication of claims denial rates for all qualified health 
     plans offering coverage on the exchange.
       ``(B) Grants to support transparency.--For purposes of 
     implementing this paragraph, there is authorized to be 
     appropriated, and there is appropriated, $5,000,000 to enable 
     the Secretary to award grants, contracts, or cooperative 
     agreements to appropriate entities or Exchanges.
       ``(3) Improving mental health and addiction equity 
     awareness.--
       ``(A) In general.--The Secretary shall award grants, 
     contracts, or cooperative agreements to appropriate entities 
     or Exchanges for the establishment of public education 
     programs to raise awareness about the availability of mental 
     health and substance use disorder benefits within qualified 
     health plans.
       ``(B) Grants to support public education.--For purposes of 
     implementing this paragraph, there is authorized to be 
     appropriated, and there is appropriated, $30,000,000 to 
     enable the Secretary to award grants, contracts, or 
     cooperative agreements to appropriate entities or Exchanges.
       ``(4) Access to medication assisted therapy.--
       ``(A) Requirement.--A qualified health plan shall provide 
     coverage for more than one Food and Drug Administration-
     approved drug that is used in the medication-assisted 
     treatment of addiction.
       ``(B) No lifetime limits.--A qualified health plan shall 
     not establish a lifetime limit on the coverage of Food and 
     Drug Administration-approved drugs used in the medication-
     assisted treatment of addiction.
       ``(C) Medical justification for treatment limitations.--
     Upon the request of an Exchange, a qualified health plan 
     shall provide the medical justification for any treatment 
     limitation on the coverage of drugs for medication-assisted 
     treatment of addiction. If a qualified health plan requires 
     prior authorization as a treatment limitation on the coverage 
     of drugs for medication-assisted treatment of addiction, such 
     plans shall utilize an automated, electronic means of 
     obtaining prior authorization.
       ``(D) Grants.--The Secretary shall award grants, contracts, 
     or cooperative agreements to support the establishment of a 
     standardized system for electronic prior authorization for 
     coverage of drugs for medication assisted treatment of 
     addiction. For purposes of implementing this subparagraph, 
     there is authorized to be appropriated, and there is 
     appropriated, $5,000,000 to enable the Secretary to ward 
     grants, contracts, or cooperative agreements to appropriate 
     entities.''.
       (b) Full Repeal of IMD Exclusion in Medicaid Expansion 
     States.--
       (1) In general.--The first sentence of section 1905 of the 
     Social Security Act (42 U.S.C. 1396d) is amended--
       (A) in subsection (a)(29), by inserting ``and subsection 
     (ee)''; and
       (B) by adding at the end the following:
       ``(ee) Nonapplication of IMD Exclusion in Medicaid 
     Expansion States.--Beginning January 1, 2016, in the case of 
     a State that makes medical assistance available pursuant to 
     section 1902(a)(10)(A)(i)(VIII) to individuals described in 
     such section--
       ``(1) the payments exclusion in subsection (a)(29)(B) shall 
     not apply to the State; and
       ``(2) the following provisions shall be applied to the 
     State as if `65 years of age or older' and `65 years of age 
     or over' were

[[Page S8386]]

     struck from such provisions each place such phrases appear:
       ``(A) Paragraphs (20) and (21) of section 1902(a).
       ``(B) Subsection(a)(14).
       ``(C) Section 1919(d)(7)(B)(i)(I).''.
       (c) Improving Access to Assertive Community Treatment 
     Programs for Medicaid Beneficiaries.--Effective January 1, 
     2016, section 1903(a)(3) of the Social Security Act (42 
     U.S.C. 1396a(a)(3)) is amended by inserting after 
     subparagraph (F) the following:
       ``(G)(i) 90 percent of so much of the sums expended during 
     such quarter as are attributable to payments made for items 
     and services provided to individuals who are eligible for 
     medical assistance under the State plan by Assertive 
     Community Treatment (ACT) programs that provide integrated, 
     evidence-based treatment, rehabilitation, case management, 
     and support services for individuals with serious mental 
     illness; and''.
       (d) Improving Access to Medication Assisted Treatment for 
     Medicaid Beneficiaries.--Effective January 1, 2016, section 
     1903(a)(3)(G) of the Social Security Act (42 U.S.C. 
     1396a(a)(3)(G)), as added by section 3, is amended by adding 
     at the end the following:
       ``(ii) 90 percent of so much of the sums expended during 
     such quarter as are attributable to payments made for items 
     and services provided to individuals who are eligible for 
     medical assistance under the State plan by person-centered 
     health homes that are focused on the treatment of substance 
     use disorders, offer access to evidence-based behavioral 
     health therapies and medication assistance treatment, and 
     offer screening and management of co-occurring physical 
     health issues and screening and management of co-occurring 
     mental health issues; and''.
       (e) Supporting State Sterile Syringe Exchange Programs.--
     Effective January 1, 2016, section 1903(a)(3)(G) of the 
     Social Security Act (42 U.S.C. 1396a(a)(3)(G)), as added by 
     section 3 and amended by section 4, is amended by adding at 
     the end the following:
       ``(iii) 90 percent of so much of the sums expended during 
     such quarter as are attributable to payments for sterile 
     syringe exchange programs (without regard to whether a 
     recipient of items and services under such a program is 
     eligible for medical assistance under the State plan or 
     otherwise has health insurance coverage); plus''.
       (f) Improving the Public Health Response to the Substance 
     Use Disorder Epidemic.--
       (1) Purpose.--It is the purpose of this subsection to 
     establish a new Substance Use and Mental Health Capacity 
     Expansion Fund (referred to in this subsection as the 
     ``Fund''), to be administered through the Department of 
     Health and Human Services, to provide for an expanded and 
     sustained national investment in the prevention and treatment 
     of individuals with substance use disorders and mental 
     illnesses.
       (2) Funding.--There is authorized to be appropriated, and 
     there is appropriated, to the Fund, out of any monies in the 
     Treasury not otherwise appropriated--
       (A) for fiscal year 2016, $500,000,000;
       (B) for fiscal year 2017, $750,000,000;
       (C) for fiscal year 2018, $1,000,000,000;
       (D) for fiscal year 2019, $1,250,000,000;
       (E) for fiscal year 2020, $1,500,000,000; and
       (F) for fiscal year 2021 and each fiscal year thereafter, 
     $2,500,000,000.
       (3) Use of fund.--The Secretary of Health and Human 
     Services shall transfer amounts in the Fund to accounts 
     serving the Block Grants for Prevention and Treatment of 
     Substance Abuse program under subpart II of part B of title 
     XIX of the Public Health Service Act (42 U.S.C. 300x-21 et 
     seq.) and the Block Grants for Community Mental Health 
     Services program under subpart I of part B of title XIX of 
     the Public Health Service Act (42 U.S.C. 300x et seq.). The 
     Fund shall be used to supplement, not supplant, funding that 
     is otherwise allocated to such programs.
       (4) Sterile syringe exchange programs.--With respect to 
     fiscal year 2016, and each subsequent fiscal year, in the 
     case of a State that operates a sterile syringe exchange 
     program, the Secretary shall use the funds appropriated in 
     this section to increase such State's allotment under subpart 
     II of part B of title XIX of the Public Health Service Act 
     for such fiscal year, by 5 percent.

     SEC. __. FAIR SHARE TAX ON HIGH-INCOME TAXPAYERS.

       (a) In General.--Subchapter A of chapter 1 of the Internal 
     Revenue Code of 1986 is amended by adding at the end the 
     following new part:

          ``PART VII--FAIR SHARE TAX ON HIGH-INCOME TAXPAYERS

``Sec. 59A. Fair share tax.

     ``SEC. 59A. FAIR SHARE TAX.

       ``(a) General Rule.--
       ``(1) Impositition of tax.--In the case of any high-income 
     taxpayer, there is hereby imposed for a taxable year (in 
     addition to any other tax imposed by this subtitle) a tax 
     equal to the product of--
       ``(A) the amount determined under paragraph (2), and
       ``(B) a fraction (not to exceed 1)--
       ``(i) the numerator of which is the excess of--

       ``(I) the taxpayer's adjusted gross income, over
       ``(II) the dollar amount in effect under subsection (c)(1), 
     and

       ``(ii) the denominator of which is the dollar amount in 
     effect under subsection (c)(1).
       ``(2) Amount of tax.--The amount of tax determined under 
     this paragraph is an amount equal to the excess (if any) of--
       ``(A) the tentative fair share tax for the taxable year, 
     over
       ``(B) the excess of--
       ``(i) the sum of--

       ``(I) the regular tax liability (as defined in section 
     26(b)) for the taxable year, determined without regard to any 
     tax liability determined under this section,
       ``(II) the tax imposed by section 55 for the taxable year, 
     plus
       ``(III) the payroll tax for the taxable year, over

       ``(ii) the credits allowable under part IV of subchapter A 
     (other than sections 27(a), 31, and 34).
       ``(b) Tentative Fair Share Tax.--For purposes of this 
     section--
       ``(1) In general.--The tentative fair share tax for the 
     taxable year is 30 percent of the excess of--
       ``(A) the adjusted gross income of the taxpayer, over
       ``(B) the modified charitable contribution deduction for 
     the taxable year.
       ``(2) Modified charitable contribution deduction.--For 
     purposes of paragraph (1)--
       ``(A) In general.--The modified charitable contribution 
     deduction for any taxable year is an amount equal to the 
     amount which bears the same ratio to the deduction allowable 
     under section 170 (section 642(c) in the case of a trust or 
     estate) for such taxable year as--
       ``(i) the amount of itemized deductions allowable under the 
     regular tax (as defined in section 55) for such taxable year, 
     determined after the application of section 68, bears to
       ``(ii) such amount, determined before the application of 
     section 68.
       ``(B) Taxpayer must itemize.--In the case of any individual 
     who does not elect to itemize deductions for the taxable 
     year, the modified charitable contribution deduction shall be 
     zero.
       ``(c) High-Income Taxpayer.--For purposes of this section--
       ``(1) In general.--The term `high-income taxpayer' means, 
     with respect to any taxable year, any taxpayer (other than a 
     corporation) with an adjusted gross income for such taxable 
     year in excess of $1,000,000 (50 percent of such amount in 
     the case of a married individual who files a separate 
     return).
       ``(2) Inflation adjustment.--
       ``(A) In general.--In the case of a taxable year beginning 
     after 2016, the $1,000,000 amount under paragraph (1) shall 
     be increased by an amount equal to--
       ``(i) such dollar amount, multiplied by
       ``(ii) the cost-of-living adjustment determined under 
     section 1(f)(3) for the calendar year in which the taxable 
     year begins, determined by substituting `calendar year 2015' 
     for `calendar year 1992' in subparagraph (B) thereof.
       ``(B) Rounding.--If any amount as adjusted under 
     subparagraph (A) is not a multiple of $10,000, such amount 
     shall be rounded to the next lowest multiple of $10,000.
       ``(d) Payroll Tax.--For purposes of this section, the 
     payroll tax for any taxable year is an amount equal to the 
     excess of--
       ``(1) the taxes imposed on the taxpayer under sections 
     1401, 1411, 3101, 3201, and 3211(a) (to the extent such tax 
     is attributable to the rate of tax in effect under section 
     3101) with respect to such taxable year or wages or 
     compensation received during such taxable year, over
       ``(2) the deduction allowable under section 164(f) for such 
     taxable year.
       ``(e) Special Rule for Estates and Trusts.--For purposes of 
     this section, in the case of an estate or trust, adjusted 
     gross income shall be computed in the manner described in 
     section 67(e).
       ``(f) Not Treated as Tax Imposed by This Chapter for 
     Certain Purposes.--The tax imposed under this section shall 
     not be treated as tax imposed by this chapter for purposes of 
     determining the amount of any credit under this chapter 
     (other than the credit allowed under section 27(a)) or for 
     purposes of section 55.''.
       (b) Clerical Amendment.--The table of parts for subchapter 
     A of chapter 1 of the Internal Revenue Code of 1986 is 
     amended by adding at the end the following new item:

         ``Part VII--Fair Share Tax on High-Income Taxpayers''.

       (c) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2015.

     SEC. __. MODIFICATION OF LIMITATION ON EXCESSIVE 
                   REMUNERATION.

       (a) Repeal of Performance-based Compensation and Commission 
     Exceptions for Limitation on Excessive Remuneration.--
       (1) In general.--Paragraph (4) of section 162(m) of the 
     Internal Revenue Code of 1986 is amended by striking 
     subparagraphs (B) and (C) and by redesignating subparagraphs 
     (D) through (G) as subparagraphs (B) through (E), 
     respectively.
       (2) Conforming amendments.--
       (A) Section 162(m)(5) of such Code is amended--
       (i) by striking ``subparagraphs (B), (C), and (D) thereof'' 
     in subparagraph (E) and inserting ``subparagraph (B) 
     thereof'', and
       (ii) by striking ``subparagraphs (F) and (G)'' in 
     subparagraph (G) and inserting ``subparagraphs (D) and (E)''.
       (B) Section 162(m)(6) of such Code is amended--
       (i) by striking ``subparagraphs (B), (C), and (D) thereof'' 
     in subparagraph (D) and inserting ``subparagraph (B) 
     thereof'', and
       (ii) by striking ``subparagraphs (F) and (G)'' in 
     subparagraph (G) and inserting ``subparagraphs (D) and (E)''.

[[Page S8387]]

       (b) Expansion of Applicable Employer.--Paragraph (2) of 
     section 162(m) of the Internal Revenue Code of 1986 is 
     amended to read as follows:
       ``(2) Publicly held corporation.--For purposes of this 
     subsection, the term `publicly held corporation' means any 
     corporation which is an issuer (as defined in section 3 of 
     the Securities Exchange Act of 1934 (15 U.S.C. 78c))--
       ``(A) the securities of which are registered under section 
     12 of such Act (15 U.S.C. 78l), or
       ``(B) that is required to file reports under section 15(d) 
     of such Act (15 U.S.C. 78o(d)).''.
       (c) Application to All Current and Former Officers, 
     Directors, and Employees.--
       (1) In general.--Section 162(m) of the Internal Revenue 
     Code of 1986, as amended by subsection (a), is amended--
       (A) by striking ``covered employee'' each place it appears 
     in paragraphs (1) and (4) and inserting ``covered 
     individual'', and
       (B) by striking ``such employee'' each place it appears in 
     subparagraphs (A) and (E) of paragraph (4) and inserting 
     ``such individual''.
       (2) Covered individual.--Paragraph (3) of section 162(m) of 
     such Code is amended to read as follows:
       ``(3) Covered individual.--For purposes of this subsection, 
     the term `covered individual' means any individual who is an 
     officer, director, or employee of the taxpayer or a former 
     officer, director, or employee of the taxpayer.''.
       (3) Conforming amendments.--
       (A) Section 48D(b)(3)(A) of such Code is amended by 
     inserting ``(as in effect for taxable years beginning before 
     January 1, 2016)'' after ``section 162(m)(3)''.
       (B) Section 409A(b)(3)(D)(ii) of such Code is amended by 
     inserting ``(as in effect for taxable years beginning before 
     January 1, 2016)'' after ``section 162(m)(3)''.
       (d) Special Rule for Remuneration Paid to Beneficiaries, 
     etc.--Paragraph (4) of section 162(m), as amended by 
     subsection (a), is amended by adding at the end the following 
     new subparagraph:
       ``(F) Special rule for remuneration paid to beneficiaries, 
     etc.--Remuneration shall not fail to be applicable employee 
     remuneration merely because it is includible in the income 
     of, or paid to, a person other than the covered individual, 
     including after the death of the covered individual.''.
       (e) Regulatory Authority.--
       (1) In general.--Section 162(m) of the Internal Revenue 
     Code of 1986 is amended by adding at the end the following 
     new paragraph:
       ``(7) Regulations.--The Secretary may prescribe such 
     guidance, rules, or regulations, including with respect to 
     reporting, as are necessary to carry out the purposes of this 
     subsection.''.
       (2) Conforming amendment.--Paragraph (6) of section 162(m) 
     of such Code is amended by striking subparagraph (H).
       (f) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2015.

     SEC. ___. MODIFICATIONS TO RULES RELATING TO INVERTED 
                   CORPORATIONS.

       (a) In General.--Subsection (b) of section 7874 of the 
     Internal Revenue Code of 1986 is amended to read as follows:
       ``(b) Inverted Corporations Treated as Domestic 
     Corporations.--
       ``(1) In general.--Notwithstanding section 7701(a)(4), a 
     foreign corporation shall be treated for purposes of this 
     title as a domestic corporation if--
       ``(A) such corporation would be a surrogate foreign 
     corporation if subsection (a)(2) were applied by substituting 
     `80 percent' for `60 percent', or
       ``(B) such corporation is an inverted domestic corporation.
       ``(2) Inverted domestic corporation.--For purposes of this 
     subsection, a foreign corporation shall be treated as an 
     inverted domestic corporation if, pursuant to a plan (or a 
     series of related transactions)--
       ``(A) the entity completes after Nov. 30, 2015, the direct 
     or indirect acquisition of--
       ``(i) substantially all of the properties held directly or 
     indirectly by a domestic corporation, or
       ``(ii) substantially all of the assets of, or substantially 
     all of the properties constituting a trade or business of, a 
     domestic partnership, and
       ``(B) after the acquisition, more than 50 percent of the 
     stock (by vote or value) of the entity is held--
       ``(i) in the case of an acquisition with respect to a 
     domestic corporation, by former shareholders of the domestic 
     corporation by reason of holding stock in the domestic 
     corporation, or
       ``(ii) in the case of an acquisition with respect to a 
     domestic partnership, by former partners of the domestic 
     partnership by reason of holding a capital or profits 
     interest in the domestic partnership.
       ``(3) Exception for corporations with substantial business 
     activities in foreign country of organization.--A foreign 
     corporation described in paragraph (2) shall not be treated 
     as an inverted domestic corporation if after the acquisition 
     the expanded affiliated group which includes the entity has 
     substantial business activities in the foreign country in 
     which or under the law of which the entity is created or 
     organized when compared to the total business activities of 
     such expanded affiliated group. For purposes of subsection 
     (a)(2)(B)(iii) and the preceding sentence, the term 
     `substantial business activities' shall have the meaning 
     given such term under regulations in effect on Nov. 30, 2015, 
     except that the Secretary may issue regulations increasing 
     the threshold percent in any of the tests under such 
     regulations for determining if business activities constitute 
     substantial business activities for purposes of this 
     paragraph.''.
       (b) Conforming Amendments.--
       (1) Clause (i) of section 7874(a)(2)(B) of such Code is 
     amended by striking ``after March 4, 2003,'' and inserting 
     ``after March 4, 2003, and before Dec. 1, 2015,''.
       (2) Subsection (c) of section 7874 of such Code is 
     amended--
       (A) in paragraph (2)--
       (i) by striking ``subsection (a)(2)(B)(ii)'' and inserting 
     ``subsections (a)(2)(B)(ii) and (b)(2)(B)'', and
       (ii) by inserting ``or (b)(2)(A)'' after ``(a)(2)(B)(i)'' 
     in subparagraph (B),
       (B) in paragraph (3), by inserting ``or (b)(2)(B), as the 
     case may be,'' after ``(a)(2)(B)(ii)'',
       (C) in paragraph (5), by striking ``subsection 
     (a)(2)(B)(ii)'' and inserting ``subsections (a)(2)(B)(ii) and 
     (b)(2)(B)'', and
       (D) in paragraph (6), by inserting ``or inverted domestic 
     corporation, as the case may be,'' after ``surrogate foreign 
     corporation''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to taxable years ending after Nov. 30, 2015.
                                 ______