On September 30th, the IRS issued proposed regulations that establish safe harbors for compliance with the employer mandate in the context of individual coverage health reimbursement arrangements (or “ICHRAs”). These proposed regulations are important for employers that choose to offer ICHRAs and want to be sure they comply with the employer shared responsibility
premium payment plan
Digging into the New HRA Regulations Part 1 – Individual Coverage HRAs
By Damian A. Myers, Kaitlin Hulbert & Malerie Bulot on
As discussed in our June 18th blog entry, the Departments of Labor, Health and Human Services, and Treasury (collectively, the “Departments”) recently released final regulations expanding the use of health reimbursement arrangements (“HRAs”). Among the more important aspects of the final regulations was the reversal of long-standing Affordable Care Act (“ACA”) policy that…
Departments Publish Final Regulations Expanding the Availability of HRAs
By Damian A. Myers, Kaitlin Hulbert & Malerie Bulot on
On June 13, 2019, the Department of Labor, together with the Department of Health and Human Services and the Department of the Treasury (collectively, the “Departments”), published final regulations designed to expand the use of health reimbursement arrangements (“HRAs”). The final regulations provide, in general, that HRAs may be used to (1) reimburse premiums for…