News & Analysis as of

Health Reimbursement Account Patient Protection and Affordable Care Act (PPACA) Department of Labor (DOL)

Verrill

December 2019 Client Advisory

Verrill on

This Client Advisory highlights important developments in the law governing employee benefit plans and executive compensation over the past year. It offers insight into what these developments mean for employers and plan...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

Proskauer - Employee Benefits & Executive...

Digging into the New HRA Regulations Part 4: Excepted Benefit HRAs

New regulations issued by the Departments of Labor, Treasury, and Health and Human Services (the “Departments”) have expanded the use of health reimbursement arrangements (“HRAs”), including permitting the use of HRAs to...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

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

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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

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

King & Spalding

Compensation and Benefits Insights - February 2019

King & Spalding on

Employers and Benefits Practitioners Eagerly Await Final Regulations on Expanded Use of HRAs - The Internal Revenue Service (IRS), Department of Labor (DOL) and Department of Health and Human Services (HHS, together with...more

Epstein Becker & Green

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

Epstein Becker & Green on

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

Laner Muchin, Ltd.

IRS Opens Discussion On Broadening The Use Of HRAs

Laner Muchin, Ltd. on

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

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

Kilpatrick

Proposed Regulations Exponentially Expand the Use of HRAs

Kilpatrick on

Health Reimbursement Accounts (HRAs) are employer funded, account-based health plans which, by design, reimburse up to a fixed dollar amount of medical expenses. The Affordable Care Act (ACA) has severely limited their use...more

Littler

WPI Insider Briefing: Will the New Composition of Federal Agencies Effect Change?

Littler on

Nine months into President Trump’s term, the pace of nominations and appointments to fill critical position within his administration is accelerating. Action on the nominations to the National Labor Relations Board (NLRB),...more

Proskauer Rose LLP

ERISA Newsletter - First Quarter 2017

Proskauer Rose LLP on

After a brief hiatus, Proskauer's ERISA Newsletter is back with a brand new look. We hope you like it and find it is easier to navigate. In addition to implementing our new format, we have moved to a quarterly publication...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

Cozen O'Connor

2016/2017 Labor & Employment Observer

Cozen O'Connor on

Activist NLRB Created More Problems For All Employers in 2016 - What Happens Under President Trump? During 2016, the National Labor Relations Board (NLRB or the Board) maintained its generally pro-union, anti-employer...more

McDermott Will & Emery

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

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

Proskauer Rose LLP

The ERISA Litigation Newsletter - December 2015

Proskauer Rose LLP on

Editor's Overview - In this month's newsletter, we focus on the recent wave of guidance and case law related to the Affordable Care Act. We also discuss IRS Notice 2015-86, which provides guidance on the application of...more

Sherman & Howard L.L.C.

End of Year Issues Impacting Employer Health Plans

Sherman & Howard L.L.C. on

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

Franczek P.C.

Employee Benefits Alert - August 2015

Franczek P.C. on

Retirement Plans - IRS Issues Guidance on Benefit Suspension Voting under MPRA - As we have written in prior alerts, the Multiemployer Pension Reform Act of 2014 (MPRA) permits trustees of financially troubled...more

Morgan Lewis

Guidance on the Application of Certain ACA Market Reforms to Employer Health Plans

Morgan Lewis on

Plan sponsors should review their health reimbursement arrangements, employer payment plans, health flexible spending arrangements, and employee assistance programs to ensure they comply with ACA market reforms....more

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