Lexology July 12, 2019
In a reversal of previous Obama Administration guidance, the Trump Administration recently finalized regulationsthat provide for a new type of health reimbursement arrangement—the individual coverage HRA. In a previous blog, we briefly discussed the potential for the individual coverage HRA to provide large employers who are subject to the Affordable Care Act (ACA) employer coverage mandate with a cost-effective alternative for meeting those requirements. To recap, under the ACA, large employers (those with 50 or more full-time employees) must offer full-time employees ACA-compliant coverage or face potential penalties. Under current rules, simply offering an HRA without also offering more traditional group health plan coverage would not satisfy those requirements.
The new regulations change that result. If the HRA meets certain...
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