News & Analysis as of

Qualified Small Employer Health Reimbursement Plan (QSEHRAs) Health Reimbursement Account Employee Benefits

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

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

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

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

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

Alston & Bird

A New Era of HRAs Begins in 2020

Alston & Bird on

A triumvirate of agencies is bringing a fresh set of health reimbursement arrangements (HRAs) to the table for 2020. Our Employee Benefits & Executive Compensation Group breaks down the nuances between the new individual...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

Snell & Wilmer

Zombie Benefits – Are Health Reimbursements Arrangements (“HRAs”) Back From the Dead?

Snell & Wilmer on

The Affordable Care Act (“ACA”) has not been kind to health reimbursement arrangements (“HRAs”). Many employers got rid of HRAs, or integrated them with a major medical plan, in order to avoid significant penalties under the...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

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

Saul Ewing LLP

IRS Provides Transitional Relief for Issuing QHCERA Notices

Saul Ewing LLP on

As described in our prior alert,the 21st Century Cures Act (“Cures Act”) allows employers with fewer than fifty employees that do not offer health plans to establish stand-alone health reimbursement arrangements (“HRAs”) to...more

Proskauer - Employee Benefits & Executive...

Notice Requirement for Small Employer HRAs Delayed Pending Regulations

On February 27, 2017, the Internal Revenue Service issued Notice 2017-20 delaying the notice requirement for qualified small employer health reimbursement arrangements (“QSEHRAs”). By way of background, prior to enactment of...more

Kilpatrick

If You Have Less than 50 Employees, Read This

Kilpatrick on

You may not yet have heard about a new type of health plan arrangement created in December 2016 for small employers – the “QSEHRA”. Many employers, particularly small employers, were adversely affected by a change in the law...more

Snell & Wilmer

Curing What Ails You – Relief for Small Employer HRAs

Snell & Wilmer on

The impact of the Affordable Care Act (“ACA”) on health reimbursement arrangements (“HRAs”) has not been favorable. Many employers got rid of their HRAs or integrated them with a major medical plan in order to avoid...more

Laner Muchin, Ltd.

Small Employers Can Ring In The New Year With A Brand New Health Reimbursement Arrangement Benefit

Laner Muchin, Ltd. on

On December 13, 2016, the 21st Century Cures Act (the Act) was signed into law. It allows small employers to offer stand-alone qualified small employer health reimbursement arrangements (QSEHRAs) to employees who have...more

Sullivan & Worcester

Employment and Benefits Advisory: 2017 Reminders and Developments

Sullivan & Worcester on

New Relief for Small Employer Health Reimbursement Arrangements - As mentioned in prior advisories, the Departments of Labor, Health and Human Services and Treasury have taken the position that employers cannot reimburse...more

Best Best & Krieger LLP

New Law Enables Small Employers to Resume Health Reimbursement Arrangements

One of the unintended consequences of the Affordable Care Act had been the elimination of health reimbursement arrangements as a tool for small employers to avoid the complexities of maintaining a group health plan and the...more

Foley & Lardner LLP

Cures Act Lets Small Employers Reiumburse Premiums

Foley & Lardner LLP on

On December 13, 2016, President Obama signed into law the 21st Century Cures Act, which allows small employers to maintain health reimbursement arrangements (HRAs) for the purpose of reimbursing employees for the cost of...more

Holland & Knight LLP

Small Employers Have New Health Reimbursement Option Under Cures Act

Holland & Knight LLP on

The 21st Century Cures Act (Cures) signed by President Barack Obama on Dec. 13, 2016, contains a smorgasbord of health-related provisions, from reforming federal mental health policies to increasing funding for medical...more

Proskauer - Employee Benefits & Executive...

Back from the Dead – Cures Act Resurrects Premium Reimbursement Arrangements for Small Employers

Last week, President Obama signed the 21st Century Cures Act (the “Cures Act”), which contains numerous provisions touching on a wide range of public health matters. Among the provisions is the creation of a new health...more

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