News & Analysis as of

Health Reimbursement Account Proposed Regulation

Foley & Lardner LLP

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

Foley & Lardner LLP on

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

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

Mintz - Employment Viewpoints

Treasury Department and IRS Proposed Individual Coverage HRA Affordability Safe Harbors

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

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

Ballard Spahr LLP

Proposed Regulations Provide Additional Guidance on Individual Coverage HRAs

Ballard Spahr LLP on

The U.S. Department of the Treasury has issued proposed regulations addressing how individual coverage health reimbursement arrangements (ICHRAs) can comply with the Employer Shared Responsibility Payments (ESRP) requirements...more

McDermott Will & Emery

Weekly IRS Roundup September 23 – 27, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 23 – 27, 2019. September 24, 2019: The IRS issued a notice that provides a safe...more

Williams Mullen

Podcast: Health Reimbursement Arrangements

Williams Mullen on

[co-author: Claire Pollock, Paralegal] In this episode of Williams Mullen's Benefits Companion, Brydon DeWitt and Claire Pollock discuss proposed health reimbursement arrangement regulations that may provide welcome relief...more

Snell & Wilmer

Seeing the Big Picture – How Proposed Health Reimbursement Arrangements Might Harmonize with Existing Law

Snell & Wilmer on

On October 29, 2018, proposed regulations were published in the Federal Register that would permit employers to offer two new types of health reimbursement arrangements (“HRAs”) that align with the requirements of the...more

Foley & Lardner LLP

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

Foley & Lardner LLP on

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

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

Verrill

December 2018 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

Mintz - Employment Viewpoints

Agencies Propose Regulations Expanding Access to Health Reimbursement Arrangements

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

Foley & Lardner LLP

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

Foley & Lardner LLP on

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

Clark Hill PLC

Agencies Propose New Health Reimbursement Arrangement Regulations

Clark Hill PLC on

New proposed regulations expand the usability and availability of health reimbursement arrangements (HRAs). Under the proposed regulations, employers could provide an HRA that is integrated with individual health coverage...more

Davis Wright Tremaine LLP

An Employer’s Guide to Proposed Regulations Expanding HRAs

Proposed IRS and DOL regulations have been issued expanding permitted uses for health reimbursement arrangements (HRAs). These proposals follow recent regulations on association health plans, both stemming from President...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

Kilpatrick

ACA Reporting – Multiple Coverage and Requesting SSNs

Kilpatrick on

Newly proposed IRS regulations seek to clarify certain aspects of reporting of minimum essential coverage by employers and issuers under Code Section 6055. Here, we focus on proposals that impact employer reporting (Part III...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 10 of 24): IRS Issues Final Form 2015...

The IRS recently issued final instructions for Forms 1094-B and 1095-B and Forms 1094-C and 1095-C . The 2015 Instructions for Forms 1094-B and 1095-B implement a suggestion we made in a previous post relating to the...more

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