News & Analysis as of

Health Insurance Employer Mandates Health Reimbursement Account

Foley & Lardner LLP

Safe Harbors for Offering Health Coverage via an Individual Coverage Health Reimbursement Arrangement

Foley & Lardner LLP on

The Internal Revenue Service (“IRS”) released final regulations... that permit employers to set aside pre-tax funds into health reimbursement arrangements (“HRAs”) that can be used by employees to pay for premiums and other...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

Bond Schoeneck & King PLLC

“Stand-Alone” HRAs Are Back – Sort Of: Individual Coverage HRAs May Offer Simpler Means For Compliance With Employer Mandate

The U.S. agencies in charge of issuing guidance under the Patient Protection and Affordable Care Act (ACA) recently finalized regulations that essentially reverse prior agency guidance on stand-alone health reimbursement...more

Proskauer - Employee Benefits & Executive...

Digging into the New HRA Regulations, Part 3 – Premium Tax Credit and Employer Mandate Impact on Individual Coverage HRAs

As part of our ongoing series on the final regulations expanding the availability of health reimbursement accounts (“HRAs”), we discussed the newly-created Individual Coverage HRAs, which generally allow for employers to...more

Foley & Lardner LLP

Final Regulations Permit Employers to Reimburse an Employee’s Costs for the Purchase of an Individual Health Insurance Policy

Foley & Lardner LLP on

Effective January 1, 2020, employers may put aside pre-tax funds into a health reimbursement arrangement (“HRA”) that can be used by an employee to pay for premiums and other out-of-pocket costs related to the purchase of an...more

Littler

Proposed Rule Expands HRA Usage and Forecasts Safe Harbors for ACA Employer Mandate Compliance

Littler on

The Departments of the Treasury, Labor, and Health and Human Services (collectively, the “Departments”) recently released a proposed rule to expand the use of health reimbursement arrangements (HRAs) and other account-based...more

Ballard Spahr LLP

IRS Issues Additional Guidance Issued on Health Reimbursement Arrangements

Ballard Spahr LLP on

The IRS has followed up on its recently proposed Health Reimbursement Arrangements (HRA) regulations with guidance on some open issues. Notice 2018-88 specifically addresses the interplay between HRAs and two Internal Revenue...more

Ballard Spahr LLP

Health Care Reform in Transition While Congress Deliberates

Ballard Spahr LLP on

Changes are imminent for the Affordable Care Act and a range of other laws and regulations affecting the health care industry. Ballard Spahr attorneys established a Health Care Reform Initiative in 2008 to monitor and analyze...more

King & Spalding

New ACA Guidance Warrants Another "Checkup" of Employer Health Plans

King & Spalding on

On December 16, 2015, the IRS issued Notice 2015-87 (the "Notice"), which provides "question-and-answer" guidance regarding how various Affordable Care Act (the "ACA") provisions apply to employer-provided group health plans....more

Ballard Spahr LLP

Reporting for ACA Mandates: Final Forms and Additional Guidance

Ballard Spahr LLP on

The IRS has finalized the 2015 forms and instructions for reporting under the individual and employer mandates and issued additional guidance on these new reporting requirements. The following forms are now available...more

Balch & Bingham LLP

Final 2015 Forms 1094-B, 1095-B, 1094-C, 1095-C and Instructions

Balch & Bingham LLP on

On September 16, 2015, the IRS finalized these ACA coverage reporting Forms and Instructions... We report here, with minimal analysis, changes that we recognized on first comparison to the 2015 Draft Forms and Instructions....more

King & Spalding

IRS Clarifies That After-Tax HRAs and Other Individual Health Insurance Payment Arrangements Generally Violate the Affordable Care...

King & Spalding on

Any employer who offers an arrangement that reimburses employees (or pays directly) for premiums or other medical costs of individual health insurance coverage, including a health reimbursement account ("HRA") provided in...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act—Countdown to Compliance for Employers, Week 6: Labor and Treasury Departments Play Whack-a-Mole with...

Last year, the Department of Labor and the Treasury Department/IRS (Departments) issued guidance on the application of certain of the Affordable Care Act’s insurance market reforms to health reimbursement arrangements (HRAs),...more

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