News & Analysis as of September 22, 2024

Employer Mandates › Health Reimbursement Account

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Employer Mandates is a term commonly used to describe employer insurance obligations under the Affordable Care Act. Under the Affordable Care Act, employers with 50 or more employees are required to provide minimum essential insurance coverage to their employees or else pay statutory penalties. The concept of an employer mandate is not unique to the Affordable Care Act; many EU countries have their own versions with different and/or expanded employer obligations. less -

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

Foley & Lardner LLP on 1/24/2020

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

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

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

Bond Schoeneck & King PLLC on 8/12/2019

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

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 Regulations Expand Use of Health Reimbursement Arrangements

McGuireWoods LLP on 7/15/2019

On June 20, the U.S. Departments of Labor, Treasury, and Health and Human Services (the Departments) released a final rule expanding the availability of health reimbursement arrangements (HRAs) employers can use to pay for or...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

Under Developing IRS Guidance (Not Final), an Employer Would Be Able to Fully Satisfy ACA’s Employer Mandate Without Maintaining...

Foley & Lardner LLP on 1/15/2019

Takeaway Message: A recent IRS notice provides a future path for employers to avoid ACA employer mandate penalties by reimbursing employees for a portion of the cost of individual insurance coverage through an...more

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

Littler on 11/28/2018

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

IRS Issues Additional Guidance Issued on Health Reimbursement Arrangements

Ballard Spahr LLP on 11/21/2018

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

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

Foley & Lardner LLP on 11/14/2018

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

Health Care Reform in Transition While Congress Deliberates

Ballard Spahr LLP on 1/20/2017

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

Recent Government-Issued FAQs Clarify ACA Employer Mandate, Market Reforms

McDermott Will & Emery on 4/2/2016

Notice 2015-87 (the Notice) provides recent government guidance on the Affordable Care Act (ACA) employer mandate and market reforms. The Notice contains 26 frequently asked questions (FAQs) from the Internal Revenue Service...more

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

King & Spalding on 3/8/2016

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

Issue 98: Year-End Agency FAQs Address Many Unanswered ACA Concerns

Seyfarth Shaw LLP on 1/18/2016

This is the ninety-eighth issue in our health care reform series of alerts for employers on selected topics in health care reform. This series of Health Care Reform Management Alerts is designed to provide a more in-depth...more

End of Year Issues Impacting Employer Health Plans

Sherman & Howard L.L.C. on 10/30/2015

With the end of 2015 fast approaching, employers should be aware of certain issues under the Patient Protection and Affordable Care Act (“ACA”), the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and...more

Reporting for ACA Mandates: Final Forms and Additional Guidance

Ballard Spahr LLP on 10/1/2015

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

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

Balch & Bingham LLP on 9/21/2015

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

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 5 of 24): Reporting of Health Reimbursement...

Mintz - Employment, Labor & Benefits... on 8/19/2015

As we reported last week, the IRS recently issued draft 2015 Instructions for Forms 1094-C and 1095-C. These instructions are of interest to applicable large employers who must report their compliance with the Affordable Care...more

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

King & Spalding on 4/9/2015

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

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

Mintz - Employment, Labor & Benefits... on 11/18/2014

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

New Guidance Clarifies Health Reimbursement Arrangements Under ACA

McDermott Will & Emery on 10/24/2013

Recently issued guidance clarifies the application of certain provisions under the Affordable Care Act (ACA) to health reimbursement arrangements, employer payment plans, health flexible spending arrangements and employee...more

PCOR Trust Fund Fee Due Soon for Many Plans

Morgan Lewis on 7/25/2013

Calendar-year plans should use updated IRS Form 720 and related instructions to file by July 31 deadline. Under the Affordable Care Act (ACA), for plan years ending on or after October 1, 2012, plan sponsors of...more

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Employer Mandates › Health Reimbursement Account

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