News & Analysis as of

Final Rules Health Reimbursement Account

Bricker Graydon LLP

Could new Individual Coverage HRAs replace your group health plan?

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Employers and employees are continually feeling the pinch of rising health care costs. 2020 provides a potentially better approach to consider: Individual Coverage Health Reimbursement Arrangements (ICHRAs)....more

Patterson Belknap Webb & Tyler LLP

Planning for 2020: Expanded HRA Options for Employers under the Final HRA Regulations

The Departments of Labor, Health and Human Services and Treasury (the “Agencies”) recently released final regulations1 that create new opportunities for employers to provide health reimbursement arrangements (“HRAs”) to...more

Williams Mullen

Health Reimbursement Arrangement Update

Williams Mullen on

On this episode of Williams Mullen's Benefits Companion, Brydon DeWitt reviews the final health reimbursement regulations that go into effect on January 1, 2020....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

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

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

Proskauer - Employee Benefits & Executive...

Digging into the New HRA Regulations, Part 2 – ERISA Implications

New regulations issued by the Departments of Labor, Treasury, and Health and Human Services have expanded the use of health reimbursement accounts (“HRAs”) by allowing reimbursements for individual market insurance premiums....more

Proskauer Rose LLP

ERISA Newsletter - Second Quarter 2019

Proskauer Rose LLP on

Editor's Overview - As the summer heats up, so too has the U.S. Supreme Court's docket for next term where it has already agreed to hear three ERISA cases and more may be in the works. On the docket already are ERISA...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

Holland & Knight LLP

New Final Rules Permit Individual Coverage Health Reimbursement Arrangements

Holland & Knight LLP on

• The U.S. Departments of Health and Human Services, Labor and the Treasury (collectively, the Departments) issued Final Rules regarding a new type of health reimbursement arrangement (HRA) – the individual coverage HRA...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

Laner Muchin, Ltd.

Federal Agencies Issue Final Regulations Expanding Availability Of HRAs

Laner Muchin, Ltd. on

On June 13, 2019, the Departments of Treasury, Labor, and Health and Human Services issued final regulations, effective January 1, 2020, that allow an employer to reimburse employee premiums for individual health insurance...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

Proskauer - Employee Benefits & Executive...

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

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

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

Beltway Buzz - June 2019 #3

Board Rules on Union Access. Late last week, the National Labor Relations Board issued a decision involving the balancing of employees’ statutory right to organize with employers’ private property rights. In the case, the...more

Ballard Spahr LLP

Coming to Market: Final Rules Issued for Individual Coverage HRAs

Ballard Spahr LLP on

The U.S. Departments of the Treasury, Labor, and Health and Human Services have issued final regulations allowing employers to establish health reimbursement arrangements and certain other types of reimbursement plans...more

Proskauer - Employee Benefits & Executive...

Departments Publish Final Regulations Expanding the Availability of HRAs

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...more

White and Williams LLP

Rules Finalized Permitting Employees to Buy Individual Health Insurance Plans through HRAs

White and Williams LLP on

On June 13, 2019, the U.S. Departments of Health and Human Services, Labor and the Treasury issued final rules that will expand the use of health reimbursement arrangements (HRAs), which are a type of account-based health...more

Dorsey & Whitney LLP

Sample ADA Notice for Wellness Programs

Dorsey & Whitney LLP on

The EEOC has published a sample notice intended to help employers comply with the notice requirement under the new Americans with Disabilities Act (ADA) final rule (published on May 17, 2016). The final rule requires...more

Balch & Bingham LLP

Five Years Later, Final Rules on Grandfathered Plan Status, Etc.

Balch & Bingham LLP on

Today, the ACA enforcement agencies (DOL, HHS, IRS) jointly published final rules, effective January 1, 2017, on grandfathered plan status, pre-existing condition exclusions, lifetime and annual limits, rescissions, dependent...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 16 of 24): Reporting for, and Clearing Up...

In an earlier post, we reported on a troubling development in the draft 2015 instructions for Forms 1094-B and 1095-B which, if adopted, would have required sponsors of Health Reimbursement Arrangements (“HRA”) to issue...more

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