Lexology June 17, 2019
Porter Wright Morris & Arthur LLP

Seemingly unfazed by the recent setbacks with the Association Health Plan regulations, the Departments of Treasury, Labor and Health and Human Services have released new health reimbursement (HRA) regulations that could reshape the group health plan landscape by providing employers with potentially cheaper options than traditional group health plan coverage for satisfying Affordable Care Act (ACA) requirements.

While we are still digesting the regulations (they come in at a whopping 497 pages), the guidance provides for two new types of health reimbursement accounts (HRAs); Individual Coverage HRAs and Excepted Benefit HRAs.

Individual Coverage HRAs

From our perspective, this is the bigger development. Currently large employers (those with 50 or more employees) must offer full-time employees ACA-compliant group health plan coverage...

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