Affordable Care Act, Health Insurance, Qualified Small Employer Health Reimbursement Plan (QSEHRAs)

Treasury Department and IRS Proposed Individual Coverage HRA Affordability Safe Harbors

Mintz - Employment Viewpoints on 11/11/2019

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

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

Proskauer - Employee Benefits & Executive... on 10/29/2019

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

A New Day for the HRA

McDermott Will & Emery on 7/30/2019

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

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

Proskauer - Employee Benefits & Executive... on 7/19/2019

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

New HRA Rules: What Employers Need to Know

Ogletree, Deakins, Nash, Smoak & Stewart,... on 7/17/2019

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

New Health Reimbursement Options Available for Employers of any Size

Poyner Spruill LLP on 7/2/2019

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

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

Foley & Lardner LLP on 6/27/2019

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

Digging into the New HRA Regulations Part 1 – Individual Coverage HRAs

Proskauer - Employee Benefits & Executive... on 6/24/2019

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...more

The Proposed Expansion of Health Reimbursement Arrangements: Is This a Game Changer for Employers?

Epstein Becker & Green on 1/10/2019

On October 22, 2018, in perhaps the most significant guidance resulting from President Trump’s 2017 Executive Order 13813, “Promoting Healthcare Choice and Competition Across the United States” (“2017 Executive Order”), the...more

IRS Opens Discussion On Broadening The Use Of HRAs

Laner Muchin, Ltd. on 12/19/2018

In October 2018, the Departments of Treasury, Labor, and Health and Human Services issued proposed regulations expanding the availability of Health Reimbursement Arrangements (HRAs) by eliminating a prohibition on integrating...more

Agencies Propose Regulations Expanding Access to Health Reimbursement Arrangements

Mintz - Employment Viewpoints on 12/13/2018

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

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

Snell & Wilmer on 11/7/2018

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

Proposed Rule Aims to Resurrect Health Reimbursement Arrangements

Ogletree, Deakins, Nash, Smoak & Stewart,... on 11/2/2018

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

Proposal for Employer Provided Health Reimbursement Accounts for Individuals to Purchase Health Insurance - A Remedy for High...

Winstead PC on 10/25/2018

First, the new proposal for Health Reimbursement Accounts/Arrangements (“HRAs”) to be used for the purchase of individual health insurance policies does not alter the annual enrollment in which many employers are currently...more

President Trump Once Again Attempts To Dismantle The Affordable Care Act

Fisher Phillips on 12/1/2017

After multiple failed attempts by Congress to reform the Affordable Care Act (ACA), President Trump announced several weeks ago that the federal government would stop making subsidy payments to insurers who sell coverage...more

21st Century Cures Act Qualified Small Employer Health Reimbursement Arrangements (“QSEHRAs”) May Not Be the Total Cure

Winstead PC on 11/3/2017

QSEHRAs are designed for employers that are not applicable large employers under the employer shared responsibility tax (Code section 4980H). QSEHRAs may only be offered by employers with fewer than 50 full-time employees (as...more

Executive Orders May Be Asking Too Much of Regulators

Carlton Fields on 10/25/2017

On October 12, President Trump signed Executive Order 13813, asking the Department of Labor (DOL) to consider allowing small employers to join together to self-insure or purchase insurance as a large group (creating...more

Update #9: New Executive Orders and Actions Could Reshape ACA in Absence of Legislation

Davis Wright Tremaine LLP on 10/25/2017

After months of Congressional attempts to “repeal and replace” the ACA ended in failure, President Trump has issued an Executive Order and taken other actions that could significantly reshape the health care market. We are...more

QSEHRA – The 21st Century Cures Act Creates a New Health Care Plan Option for Small Employers

Mintz - Employment Viewpoints on 3/31/2017

The 21st Century Cures Act (Cures Act), enacted on December 13, 2016, provides a new opportunity for small employers to help employees pay for health insurance: the “qualified small employer health reimbursement arrangement”...more

Update #5: It’s Here! House Republicans Propose ACA Replacement – Key Provisions for Employers

Davis Wright Tremaine LLP on 3/8/2017

The House Ways and Means and Energy and Commerce Committees have issued draft legislation, the American Health Care Act, to begin the process of repealing and replacing the Affordable Care Act. Both Committees will hold...more

A New Employer Healthcare Plan: Qualified Small Employer Health Reimbursement Arrangement (QSEHRA)

Fisher Phillips on 3/6/2017

Until very recently, employers were at risk of receiving steep fines if they reimbursed employees for non-employer sponsored medical care – the Affordable Care Act (ACA) included fines of up to $36,500 a year per employee for...more

Notice Requirement for Small Employer HRAs Delayed Pending Regulations

Proskauer - Employee Benefits & Executive... on 3/1/2017

On February 27, 2017, the Internal Revenue Service issued Notice 2017-20 delaying the notice requirement for qualified small employer health reimbursement arrangements (“QSEHRAs”). By way of background, prior to enactment of...more

QSEHRAs: End-of-Year Legislation Provides a New Health Care Option for Small Employers

Alston & Bird on 12/30/2016

Tucked at the end of the recently enacted 300-plus-page 21st Century Cures Act (Cures Act) is a provision that offers certain small employers a new opportunity to help employees purchase individual market major medical...more

New ACA FAQs - Special Enrollment, Women’s Preventive Care and a Cure for the HRA that Ails You (If You’re Small Enough)

BCLP on 12/28/2016

In the latest round of FAQs on ACA implementation (now up to 35 if you’re keeping track), the DOL, HHS and Treasury Department addressed questions regarding HIPAA special enrollment rights, ACA coverage for preventive...more

Small Employers Have New Health Reimbursement Option Under Cures Act

Holland & Knight LLP on 12/22/2016

The 21st Century Cures Act (Cures) signed by President Barack Obama on Dec. 13, 2016, contains a smorgasbord of health-related provisions, from reforming federal mental health policies to increasing funding for medical...more

Patient Protection and Affordable Care Act (PPACA) › Health Insurance › Qualified Small Employer Health Reimbursement Plan (QSEHRAs)

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