News & Analysis as of

Health Reimbursement Account Department of Health and Human Services (HHS) Department of Labor (DOL)

Faegre Drinker Biddle & Reath LLP

Reminder: Gag Clause Attestations Due by Year-End

The Consolidated Appropriations Act of 2021 generally requires group health plans and health insurance issuers to submit a Gag Clause Prohibition Compliance Attestation (Attestation) each year to demonstrate compliance with...more

Ballard Spahr LLP

Gag-Clause Attestations Due by End of Year

Ballard Spahr LLP on

Summary - By December 31, 2023, health plans and insurers must submit an attestation of compliance with the anti-gag rules of the Consolidated Appropriations Act, 2021 (CAA). The rules apply to all agreements entered into...more

Sherman & Howard L.L.C.

Gag Clause Compliance Attestation Requirements for Plan Sponsors

Since 2021, certain group health plans and health insurance issuers have been prohibited from entering into agreements with “gag clauses” (“Gag Clause Prohibition”). By December 31, 2023, these plans and issuers will be...more

Seyfarth Shaw LLP

Final Rule regarding Transparency in Coverage for Health Care Services

Seyfarth Shaw LLP on

Seyfarth Comments: The final Transparency in Coverage Rule was published jointly by the Departments of Health and Human Services, Treasury, and Labor on November 12, 2020. The Rule aims to increase transparency in...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Texas Insurance Commissioner Issues Bulletin Clarifying Applicability of Texas Small and Large Employer Health Plan Requirements...

On Thursday, February 20, 2020, the Commissioner of the Texas Department of Insurance issued a bulletin clarifying the applicability of Texas’ small and large employer health plan laws and regulations to individual coverage...more

Fisher Phillips

Health Reimbursement Arrangements: What Employers Need To Know And Avoid

Fisher Phillips on

Health Reimbursement Arrangements (HRAs) are account-based health plans funded with employer contributions to reimburse eligible participants and dependents for medical expenses. Prior to the Affordable Care Act, HRAs were...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

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

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

Jackson Lewis P.C.

FYI – New HRA Options In 2020

Jackson Lewis P.C. on

Health Reimbursement Arrangements (HRA) have been around for years and are an outstanding benefit to help employees enrolled in an employer’s group health plan pay for their insurance premiums. What happens though when an...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

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

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

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

Lathrop GPM

2014 – June, 30 2015 Relief from Employer Excise Tax for Small Employer & S Corporation Payment or Reimbursement of Individual...

Lathrop GPM on

Beginning in 2014, a violation of certain healthcare reform rules, such as offering a health plan with annual dollar limits or not providing full preventive care with no employee cost, requires employers to pay an excise tax...more

Perkins Coie

The Affordable Care Act Creates Compliance Challenges For HRAs And Other Arrangements

Perkins Coie on

On September 13, 2013 the U.S. Department of the Treasury (IRS), the U.S. Department of Health and Human Services (HHS), and the U.S. Department of Labor (DOL), collectively referred to herein as the Departments, coordinated...more

Franczek P.C.

Monthly Benefits Update - September 2013

Franczek P.C. on

Health & Welfare Plans - Health Care Reform: FAQ Part XVI Addresses Insurance Exchange Notice and 90-Day Waiting Period Requirement. The Treasury, the Department of Labor and the Department of Health and Human...more

Mintz - Employment, Labor & Benefits...

DOL, IRS, and HHS Put the Brakes on Stand-Alone HRAs Used to Access Health Insurance Coverage in the Individual Market

In a set of Frequently Asked Questions (FAQs) posted to the Department of Labor’s website on January 24, the Departments of Health and Human Services, Labor, and Treasury (the “Departments”) put a stop to an approach to...more

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