News & Analysis as of

Employee Benefits Qualified Small Employer Health Reimbursement Plan (QSEHRAs)

Bricker Graydon LLP

Which Should You Choose: Health Savings Accounts vs. Health Reimbursement Accounts

Bricker Graydon LLP on

When it comes to pre-tax savings for qualifying medical expenses, employers have several options available to offer employees. Two of the more popular options are health savings accounts (HSAs) and health reimbursement...more

Woodruff Sawyer

IRS Adjusts Health Flexible Spending Account and Other Benefit Limits for 2024

Woodruff Sawyer on

On November 9,2023, the Internal Revenue Service (IRS) released Revenue Procedure 2023-34, which increases the health flexible spending account (FSA) salary reduction contribution limit to $3,200 for plan years beginning in...more

Husch Blackwell LLP

Federal Government Issues New ERISA Disclosure Requirements: DOL guidance triggers important responsibilities for both service...

Husch Blackwell LLP on

On December 30, 2021, the Department of Labor (DOL) issued a temporary enforcement policy and guidance regarding group health plan service provider disclosures under section 408(b)(2) of the Employee Retirement Income...more

Proskauer - Employee Benefits & Executive...

All Good Subsidies Must Come to an End, Part II: The IRS Adds Some Nuances

In an earlier post we reviewed the end dates for the ARP COBRA premium subsidy provided by the American Rescue Plan Act of 2021 (“ARP”), and addressed the required expiration notice.  This post revisits the topic in light of...more

Smith Anderson

ARPA COBRA Subsidy's Impact on Employer Health Plans

Smith Anderson on

The American Rescue Plan Act of 2021 (ARPA) provides temporary COBRA continuation coverage premium assistance for certain eligible qualified beneficiaries. On April 7, 2021, the Department of Labor issued a FAQ and model...more

Seyfarth Shaw LLP

IRS Announces 2021 Limits for Certain Health and Fringe Benefit Options

Seyfarth Shaw LLP on

Seyfarth Synopsis: The IRS has announced the adjustments to key limits for certain health and welfare benefit programs, including HDHP deductibles, HSA and FSA contributions, and other fringe benefit options for 2021....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Texas Insurance Commissioner Issues Bulletin Clarifying Applicability of Texas Small and Large Employer Health Plan Requirements...

On Thursday, February 20, 2020, the Commissioner of the Texas Department of Insurance issued a bulletin clarifying the applicability of Texas’ small and large employer health plan laws and regulations to individual coverage...more

Mintz - Employment Viewpoints

Treasury Department and IRS Proposed Individual Coverage HRA Affordability Safe Harbors

As we previously reported, on June 13, the Departments of Health and Human Services, Labor, and the Treasury (collectively, the “Departments”) issued a coordinated set of final regulations (“final rules”) permitting employers...more

Proskauer - Employee Benefits & Executive...

New HRA Regulations Part 5 – More on the Employer Shared Responsibility Mandate

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...more

Snell & Wilmer

Zombie Benefits Part II: Health Reimbursement Arrangements (“HRAs”) Are Back From the Dead

Snell & Wilmer on

As reported in our November 7, 2018 SW Benefits Blog Zombie Benefits – Are Health Reimbursement Arrangements (“HRAs”) Back From the Dead?, the Departments of Health and Human Services, Labor, and Treasury (the “Agencies”)...more

McDermott Will & Emery

A New Day for the HRA

McDermott Will & Emery on

The Departments of Labor, Treasury, and Health and Human Services have released final rules removing the prohibition on pairing HRAs with individual health policies. The final rules also allow certain HRAs and other...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

New HRA Rules: What Employers Need to Know

Starting in 2020, employers will be able to offer health reimbursement arrangements (HRAs) that work in conjunction with individual coverage or Medicare without running afoul of the Affordable Care Act’s (ACA) market reform...more

Burr & Forman

What the HRA is going on with HRAs?

Burr & Forman on

On June 13, the Departments of Labor, Treasury and Health and Human Services jointly released final regulations dealing with health reimbursement accounts (“HRAs”). These regulations fulfill the Trump administration’s...more

Mintz - Employment Viewpoints

Agencies Issue Final Regulations Expanding Access to Health Reimbursement Arrangements

On June 13, 2019, the Department of Health and Human Services (HHS), the Department of Labor (DOL), the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) (collectively, the “Departments”)...more

Poyner Spruill LLP

New Health Reimbursement Options Available for Employers of any Size

Poyner Spruill LLP on

One potentially unintended consequence of the Affordable Care Act (ACA) was the demise of the average health reimbursement account (HRA). Such benefits were seen to violate the ACA prohibitions on annual and lifetime limits,...more

Alston & Bird

A New Era of HRAs Begins in 2020

Alston & Bird on

A triumvirate of agencies is bringing a fresh set of health reimbursement arrangements (HRAs) to the table for 2020. Our Employee Benefits & Executive Compensation Group breaks down the nuances between the new individual...more

Mintz - Employment Viewpoints

Agencies Propose Regulations Expanding Access to Health Reimbursement Arrangements

Health Reimbursement Arrangements (or “HRAs”) are employer-funded, account-based group health plans, which are used to reimburse certain medical expenses incurred by eligible employees, their spouses, and their dependents....more

Brownstein Hyatt Farber Schreck

2019 Increases for Employee Benefits-Related Limits

Annually, the Internal Revenue Service, the Social Security Administration and the Pension Benefit Guaranty Corporation adjust for cost-of-living increases certain limitations that impact employee benefit plans. These...more

Foley & Lardner LLP

Proposed Regulations Would Permit Employers to Reimburse an Employee’s Premium Costs for a Health Insurance Policy Purchased in...

Foley & Lardner LLP on

Takeaway Message: Except in limited circumstances, current regulatory guidance prohibits an employer from maintaining a health reimbursement arrangement (HRA) that reimburses the cost of premiums for individual health...more

Snell & Wilmer

Zombie Benefits – Are Health Reimbursements Arrangements (“HRAs”) Back From the Dead?

Snell & Wilmer on

The Affordable Care Act (“ACA”) has not been kind to health reimbursement arrangements (“HRAs”). Many employers got rid of HRAs, or integrated them with a major medical plan, in order to avoid significant penalties under the...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Proposed Rule Aims to Resurrect Health Reimbursement Arrangements

Under a proposed rule that the Department of Labor (DOL), Department of the Treasury, and the Department of Health and Human Services (HHS) jointly issued on October 29, 2018, employers may soon have more flexibility to fund...more

Davis Wright Tremaine LLP

An Employer’s Guide to Proposed Regulations Expanding HRAs

Proposed IRS and DOL regulations have been issued expanding permitted uses for health reimbursement arrangements (HRAs). These proposals follow recent regulations on association health plans, both stemming from President...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Beltway Buzz - October, 2018 #4

Agencies Propose HRA Expansion. On October 23, 2018, the U.S. Department of the Treasury, U.S. Department of Health and Human Services, and U.S. Department of Labor issued a proposed regulation to expand the use of health...more

Winstead PC

When Is Your ERISA Plan or Flexible Benefit Plan Not Good Enough to Be a Bona Fide Plan?

Winstead PC on

Employee benefit plan drafters frequently complete plan documents for their client’s use assuming that the document’s status as an employee benefit plan under the Employee Retirement Income Security Act of 1974 (‘‘ERISA’’) or...more

Brownstein Hyatt Farber Schreck

Employee Benefits-Related Limits for 2018

Periodically, the Internal Revenue Service, the Social Security Administration and the Pension Benefit Guaranty Corporation adjust for cost-of-living increases certain limitations that impact employee benefit plans. These...more

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