Federal regulators issued two new developments related to health care reform: 1) A model notice of HIPAA privacy practices with versions for health plans and providers to use; and 2) New guidance on applying health care reform to HRAs, health FSAs, and other arrangements. The new guidance indicates stand-alone HRAs are no longer viable unless integrated with group health coverage by meeting restrictive conditions. It also addresses health FSAs, EAPs, and employer-paid premium arrangements. The guidance is intended to coordinate previous rules and fill gaps, clarifying that tax-favored employer health coverage must comply with reform laws.
On Nov. 8, 2013, the DOL, HHS and the Treasury released Frequently Asked Questions (FAQs) regarding implementation of the Mental Health Parity and Addiction Equity Act. These FAQs were released in conjunction with final rules on the MHPAEA, which contain some clarification regarding the law's protections.
Health Reform Alert - Implementation Guidance FAQsCBIZ, Inc.
The ACA’s governing agencies (Labor, HHS and IRS) have issued their 18th set of implementation FAQs, further defining certain aspects of the Affordable Care Act, as well as how the law coordinates with the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA). Following are highlights of this guidance.
Learn more at www.cbiz.com
Health Reform Bulletin 143 | Status of ACA Litigation; Murky Future of AHPs; ...CBIZ, Inc.
Litigation challenging and rescinding various aspects of the Affordable Care Act (ACA) continues to reign. Last December, Judge Reed O’Connor of the Fifth Circuit Court of Appeals opined that the individual mandate, in the absence of the tax repealed by the Tax Cuts and Jobs Act, is unconstitutional; and since it is a cornerstone of the ACA, then the entire ACA must fall (see our prior CBIZ Health Reform Bulletin 142).
Health Reform Bulletin 125 | Updated Employer Shared Responsibility Guidance,...CBIZ, Inc.
The latest HRB has been released. Get updates on the following: 1) Updated Employer Shared Responsibility Guidance; 2) ACA Implementation Guidance; 3) Gender Identity Discrimination: Preliminary Injunction Issued; 4) Final Rules - Premium Tax Credit; and 5) 2018 Benefit and Payment Parameters.
On Nov. 8, 2013, the DOL, HHS and the Treasury released Frequently Asked Questions (FAQs) regarding implementation of the Mental Health Parity and Addiction Equity Act. These FAQs were released in conjunction with final rules on the MHPAEA, which contain some clarification regarding the law's protections.
Health Reform Alert - Implementation Guidance FAQsCBIZ, Inc.
The ACA’s governing agencies (Labor, HHS and IRS) have issued their 18th set of implementation FAQs, further defining certain aspects of the Affordable Care Act, as well as how the law coordinates with the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA). Following are highlights of this guidance.
Learn more at www.cbiz.com
Health Reform Bulletin 143 | Status of ACA Litigation; Murky Future of AHPs; ...CBIZ, Inc.
Litigation challenging and rescinding various aspects of the Affordable Care Act (ACA) continues to reign. Last December, Judge Reed O’Connor of the Fifth Circuit Court of Appeals opined that the individual mandate, in the absence of the tax repealed by the Tax Cuts and Jobs Act, is unconstitutional; and since it is a cornerstone of the ACA, then the entire ACA must fall (see our prior CBIZ Health Reform Bulletin 142).
Health Reform Bulletin 125 | Updated Employer Shared Responsibility Guidance,...CBIZ, Inc.
The latest HRB has been released. Get updates on the following: 1) Updated Employer Shared Responsibility Guidance; 2) ACA Implementation Guidance; 3) Gender Identity Discrimination: Preliminary Injunction Issued; 4) Final Rules - Premium Tax Credit; and 5) 2018 Benefit and Payment Parameters.
HHS Extends Transition Policy for Non-ACA Compliant Health PlansKelley M. Bendele
Due to President Donald Trump's executive order directing federal agencies to provide relief from the burdens of the ACA, HHS is now promoting the availability of these waivers.
Health Care Reform -- 2016 Compliance Checklistntoscano50
The Affordable Care Act (ACA) has made a number of significant changes to group health plans since the law was enacted over four years ago. Many of these key reforms became effective in 2014 and 2015, including health plan design changes, increased wellness program incentives and the employer shared responsibility penalties.
Additional reforms take effect in 2016 for employers sponsoring group health plans. To prepare for 2016, employers should review upcoming requirements and develop a compliance strategy.
http://www.symbiusmedical.com/ - This article can help you navigate the often misunderstood new world of healthcare - the Affordable Care Act. As of 2014 non-grandfathered individual and small group health plans must provide the essential health benefits (EHBs). EHBs will include items & services in 10 statutory benefit categories. Individuals are able to shop for insurance coverage on state health insurance exchanges, called “marketplaces.” The article is written by Symbius Medical Corporate Compliance Manager, Natalie Franklin.
Although many key reforms of the Affordable Care Act (ACA) are effective for 2014, additional reforms will become effective in 2015 for employers sponsoring group health plans. For 2015, the most significant ACA change is the shared responsibility penalty for applicable large employers. To prepare for 2015, employers should review upcoming requirements and develop a compliance strategy. This Legislative Brief provides a health care reform checklist for 2015.
Health Reform Bulletin 128 | House Passes the American Health Care ActCBIZ, Inc.
On May 4, 2017, the House passed the American Health Care Act of 2017 (“AHCA”, H. R. 1628). Since the initial bill was officially introduced on March 20, 2017 (see The GOP Proposal to Repeal and Replace the Affordable Care Act, HRB 127, 3/10/17), there have been several amendments made to the law’s text. The bill will now progress to the Senate for consideration; its fate in the Senate is unclear at this point. Every indication is that the bill with undergo significant scrutiny and probably substantial change. Following is a brief overview of certain provisions of the bill passed by the House.
Healthcare check in the latest developments in health and welfare plansbenefitexpress
We work in an exciting industry—which means quick changes are the norm, and adaptability is a necessity.
Keep your compliance plan up-to-date with a download of recent legislative changes.
We'll cover legislation that's passed, what's on the way, and what it means for your organization.
Topics Covered Include:
• IRS Information Letters
• Tax Reform Legislation
• Wellness Regulations - EEOC, AARP
• Comprehensive Guidance on QSEHRAs
• ACA: Elimination of Individual Mandate Penalty
• Employer Tax Credit for Paid Family and Medical Leave
• DOL Annual Adjustments to Employee Benefit Plan Penalties
• “Good Faith” Penalty Relief
• Final Disability Claim Regulations
• Cadillac Tax Updates
• And More!
Presented by Larry Grudzien, Attorney at Law
The Affordable Care Act (ACA) specifically sets aside certain benefits as “excepted” from the law’s key requirements. These excepted benefits include the ban on annual benefit limits and waiting periods exceeding 90 days, rules governing distribution of Summary of Benefit and Coverage statements and cost-sharing limits.
If the employer mandate is repealed, many ALEs will likely want to modify their plan designs to go back to pre-ACA eligibility rules. Employers may also consider increasing the amount that employees are required to contribute for group health plan coverage.
HHS Extends Transition Policy for Non-ACA Compliant Health PlansKelley M. Bendele
Due to President Donald Trump's executive order directing federal agencies to provide relief from the burdens of the ACA, HHS is now promoting the availability of these waivers.
Health Care Reform -- 2016 Compliance Checklistntoscano50
The Affordable Care Act (ACA) has made a number of significant changes to group health plans since the law was enacted over four years ago. Many of these key reforms became effective in 2014 and 2015, including health plan design changes, increased wellness program incentives and the employer shared responsibility penalties.
Additional reforms take effect in 2016 for employers sponsoring group health plans. To prepare for 2016, employers should review upcoming requirements and develop a compliance strategy.
http://www.symbiusmedical.com/ - This article can help you navigate the often misunderstood new world of healthcare - the Affordable Care Act. As of 2014 non-grandfathered individual and small group health plans must provide the essential health benefits (EHBs). EHBs will include items & services in 10 statutory benefit categories. Individuals are able to shop for insurance coverage on state health insurance exchanges, called “marketplaces.” The article is written by Symbius Medical Corporate Compliance Manager, Natalie Franklin.
Although many key reforms of the Affordable Care Act (ACA) are effective for 2014, additional reforms will become effective in 2015 for employers sponsoring group health plans. For 2015, the most significant ACA change is the shared responsibility penalty for applicable large employers. To prepare for 2015, employers should review upcoming requirements and develop a compliance strategy. This Legislative Brief provides a health care reform checklist for 2015.
Health Reform Bulletin 128 | House Passes the American Health Care ActCBIZ, Inc.
On May 4, 2017, the House passed the American Health Care Act of 2017 (“AHCA”, H. R. 1628). Since the initial bill was officially introduced on March 20, 2017 (see The GOP Proposal to Repeal and Replace the Affordable Care Act, HRB 127, 3/10/17), there have been several amendments made to the law’s text. The bill will now progress to the Senate for consideration; its fate in the Senate is unclear at this point. Every indication is that the bill with undergo significant scrutiny and probably substantial change. Following is a brief overview of certain provisions of the bill passed by the House.
Healthcare check in the latest developments in health and welfare plansbenefitexpress
We work in an exciting industry—which means quick changes are the norm, and adaptability is a necessity.
Keep your compliance plan up-to-date with a download of recent legislative changes.
We'll cover legislation that's passed, what's on the way, and what it means for your organization.
Topics Covered Include:
• IRS Information Letters
• Tax Reform Legislation
• Wellness Regulations - EEOC, AARP
• Comprehensive Guidance on QSEHRAs
• ACA: Elimination of Individual Mandate Penalty
• Employer Tax Credit for Paid Family and Medical Leave
• DOL Annual Adjustments to Employee Benefit Plan Penalties
• “Good Faith” Penalty Relief
• Final Disability Claim Regulations
• Cadillac Tax Updates
• And More!
Presented by Larry Grudzien, Attorney at Law
The Affordable Care Act (ACA) specifically sets aside certain benefits as “excepted” from the law’s key requirements. These excepted benefits include the ban on annual benefit limits and waiting periods exceeding 90 days, rules governing distribution of Summary of Benefit and Coverage statements and cost-sharing limits.
If the employer mandate is repealed, many ALEs will likely want to modify their plan designs to go back to pre-ACA eligibility rules. Employers may also consider increasing the amount that employees are required to contribute for group health plan coverage.
Health Reform Bulletin 116 | Year-End Wrap Up Dec. 29, 2015CBIZ, Inc.
The government is winding up 2015 and ringing in 2016 with a bang. The final HRB of 2015 will keep you abreast of the various changes that occurred at the end of the year.
Health Reform Bulletin 116 Year End Wrap Up 12-29-15Daniel Michels
The most recent CBIZ Health Reform Bulletin: Year-End Wrap Up (HRB 116). This issue includes specific information and guidance on:
1. Late breaking development, IRS delays new Affordable Care Act's (ACA) reporting and disclosure obligations!
2. On December 18, 2015 Consolidate Appropriations Act, 2016, and the Protecting Americans from Tax Hikes (PATH) Act of 2015 (H. R. 2029; now Public Law No. 114-113) were signed by the President, and amend several provisions of the Affordable Care Act.
3. The IRS Issued guidance relating to ACA implementation
4. Year-End Reminders
Health Reform: Interim Guidance on Expatriate Plans; Updates on ACA Reportin...CBIZ, Inc.
This Health Care Reform Bulletin provides information on the following topics:
a. Interim Guidance on Expatriate Health Coverage
b. Updates on Section 6055/6056 Reporting
i. Revised and Increased Reporting Penalties
ii. E-filing requirements for Employers
c. Final Rules: Preventive Services
d. Reminder on PCOR Fees and Transitional Reinsurance
i. Checklist for PCOR and Transitional Reinsurance Fee
Are you ready for the upcoming 2014 provisions of the new healthcare reform act? Do you know what the implications are to you as a small or midsize company?
Our webinar will help you become familiar with upcoming requirements under the Patient Protection and Affordable Care Act.
Expect to learn the following and more:
What is the Patient Protection and Affordable Care Act
How does an organization determine their 2014 cost to comply?
What should organizations be doing now to prepare?
Health Reform Bulletin 133 | Executive Order Directing Modifications to the A...CBIZ, Inc.
An Executive Order, signed on October 12, 2017, promotes modifications of certain aspects of the Affordable Care Act (ACA) (also see press statement). In a nutshell, this Executive Order directs the ACA’s governing agencies (Health and Human Services/Labor/Treasury) to address three
elements: formation of association health plans, expansion of short-term, limited-duration insurance, and expanding the rules to allow individual premium to be reimbursed through health reimbursement arrangements (HRAs). Briefly, this Executive Order directs the governing agencies to
The article below describes a new health care reform development (additional federal agency guidance on prohibition of premium reimbursement arrangements).
The Affordable Care Act (ACA) includes certain market reforms that apply to group health plans and health insurance issuers in the group and individual markets.
On Nov. 18, 2015, the Departments of Labor (DOL), Health and Human Services (HHS) and the Treasury (Departments) published final regulations regarding a number of the ACA’s market reform requirements.
Learn how you can successfully navigate the Affordable Care Act, "Obama Care".
This easy to read outline will benefit your family and business.
Call (816-224-9466) for more information today.
Compliance Overview - Employee Benefits Compliance Checklist for Large Employersntoscano50
Federal law imposes numerous requirements on the group health coverage that employers provide to their employees. Many federal compliance laws apply to all group health plans, regardless of the size of the sponsoring employer. However, there are some additional requirements for large employers. For this purpose, a large employer is one with 50 or more employees.
Unlike smaller employers, large employers must comply with the Affordable Care Act’s (ACA) employer shared responsibility rules, the ACA’s Form W-2 reporting rules and the Family and Medical Leave Act’s (FMLA) requirements.
This Compliance Overview provides a checklist for employee benefit laws applicable to large employers.
ReadingsHealth Care Reform and Future PossibilitiesIntroduct.docxsodhi3
Readings
Health Care Reform and Future Possibilities
Introduction
Health care has undergone episodes of major change since the introduction of Medicare in the 1960s. All of these have resulted in fundamental changes in how health care providers were paid for services to Medicare patients and were swiftly followed by matching changes from independent insurance companies. The latest, and some might say the biggest, change since diagnosis-related groups (DRGs) were introduced in 1983 is the signing into law of the Patient Protection and Affordable Care Act (PPACA), on March 23, 2010. This law proposes to change the delivery of health care services by changing how providers are paid and what they are paid for. This module explores some of the key elements of PPACA and how health care providers are planning their changes in delivery processes and systems in response.
Major Elements of PPACA
The most significant elements of the PPACA legislation are scheduled to take place over several years. Congress still has the ability to modify some of these elements, so we will examine them with that in mind.
June 2010
Adults with pre-existing conditions were eligible to join a temporary high-risk insurance pool run by the federal government. This will be replaced by a health care exchange in 2014, which will provide access to insurance at affordable rates. Applicants must have a pre-existing health care condition and have been uninsured in the six months prior to application. Premiums will be set at rates for the general population rather than the high-risk premiums charged by insurance companies. Out-of-pocket costs will be limited to $5,950 for individuals and $11,900 for families.
July 2010
The government established the National Prevention, Health Promotion, and Public Health Council, with the Surgeon General to act as chair of the council. This council will oversee the implementation of many of the PPACA elements and will disseminate recommendations to the health care community at large in regard to best practices in prevention and health promotion. As of fall 2010, little had yet been heard from this entity. However, the National Committee on Quality Assurance, which is a private entity dedicated to improving the quality of health care services, is providing best practices and quality measures for health care providers, especially hospitals.
September 2010
Insurance companies can no longer apply lifetime dollar limits on essential benefits for patients. In addition, children may be covered under their parents' insurance plan until they turn 26 years of age. This includes children not living at home, not listed as dependents on their parents' tax returns, not students, and children who are married. Further, no patients under 19 years of age with pre-existing conditions can be excluded from health care benefits based on the pre-existing conditions, and there can be no deductibles or copayments required for provision of preventive care measures and medic ...
Health Reform Bulletin – IRS PronouncementsCBIZ, Inc.
Information on 1) Cafeteria Plan Status Change Events, 2) Employment Status Change Proposals to Employer Shared Responsibility Rules, 3) Increase in PCOR Fees, and Final Excepted Benefit Regulations. Recently, the Internal Revenue Service (IRS) released three pronouncements relating to the Affordable Care Act (ACA). In addition, final regulations have been issued relating to certain excepted health benefits.
Similar to News Flash: September 16, 2013 – Federal Regulators Have Been Busy; Two New Developments (20)
The survey, represents more than 500 participants ranging from 100 to more than 10,000 employees, gathers information on benefit plan designs and costs, eligibility, and health benefits strategy.
News Flash January 27 2015 - Settled Law Changing _ Retiree Medical Benefits...Annette Wright, GBA, GBDS
The following article describes a new employee benefits development (Supreme Court decision could make it easier for employers to reduce union retiree health benefits).
31052024_First India Newspaper Jaipur.pdfFIRST INDIA
Find Latest India News and Breaking News these days from India on Politics, Business, Entertainment, Technology, Sports, Lifestyle and Coronavirus News in India and the world over that you can't miss. For real time update Visit our social media handle. Read First India NewsPaper in your morning replace. Visit First India.
CLICK:- https://firstindia.co.in/
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01062024_First India Newspaper Jaipur.pdfFIRST INDIA
Find Latest India News and Breaking News these days from India on Politics, Business, Entertainment, Technology, Sports, Lifestyle and Coronavirus News in India and the world over that you can't miss. For real time update Visit our social media handle. Read First India NewsPaper in your morning replace. Visit First India.
CLICK:- https://firstindia.co.in/
#First_India_NewsPaper
03062024_First India Newspaper Jaipur.pdfFIRST INDIA
Find Latest India News and Breaking News these days from India on Politics, Business, Entertainment, Technology, Sports, Lifestyle and Coronavirus News in India and the world over that you can't miss. For real time update Visit our social media handle. Read First India NewsPaper in your morning replace. Visit First India.
CLICK:- https://firstindia.co.in/
#First_India_NewsPaper
role of women and girls in various terror groupssadiakorobi2
Women have three distinct types of involvement: direct involvement in terrorist acts; enabling of others to commit such acts; and facilitating the disengagement of others from violent or extremist groups.
‘वोटर्स विल मस्ट प्रीवेल’ (मतदाताओं को जीतना होगा) अभियान द्वारा जारी हेल्पलाइन नंबर, 4 जून को सुबह 7 बजे से दोपहर 12 बजे तक मतगणना प्रक्रिया में कहीं भी किसी भी तरह के उल्लंघन की रिपोर्ट करने के लिए खुला रहेगा।
In a May 9, 2024 paper, Juri Opitz from the University of Zurich, along with Shira Wein and Nathan Schneider form Georgetown University, discussed the importance of linguistic expertise in natural language processing (NLP) in an era dominated by large language models (LLMs).
The authors explained that while machine translation (MT) previously relied heavily on linguists, the landscape has shifted. “Linguistics is no longer front and center in the way we build NLP systems,” they said. With the emergence of LLMs, which can generate fluent text without the need for specialized modules to handle grammar or semantic coherence, the need for linguistic expertise in NLP is being questioned.
हम आग्रह करते हैं कि जो भी सत्ता में आए, वह संविधान का पालन करे, उसकी रक्षा करे और उसे बनाए रखे।" प्रस्ताव में कुल तीन प्रमुख हस्तक्षेप और उनके तंत्र भी प्रस्तुत किए गए। पहला हस्तक्षेप स्वतंत्र मीडिया को प्रोत्साहित करके, वास्तविकता पर आधारित काउंटर नैरेटिव का निर्माण करके और सत्तारूढ़ सरकार द्वारा नियोजित मनोवैज्ञानिक हेरफेर की रणनीति का मुकाबला करके लोगों द्वारा निर्धारित कथा को बनाए रखना और उस पर कार्यकरना था।
News Flash: September 16, 2013 – Federal Regulators Have Been Busy; Two New Developments
1. News Flash: September 16, 2013 – Federal Regulators Have Been Busy; Two New
Developments
Late Friday, federal regulators issued guidance under the health care reform law regarding HRAs,
health FSAs and certain other benefits. As we were preparing to send our article on that
development, we got word that HHS issued a model notice of HIPAA privacy practices this
morning. These two developments are covered in separate articles below.
HHS Issues Model Notice of HIPAA Privacy Practices
Employers working to revise their notices of HIPAA privacy practices in time for the September
23 deadline for revisions may or may not be grateful for HHS’ assistance, but the agency has
issued several versions of a model notice of HIPAA privacy practices. The HHS posting includes
two separate model notices – one for health care providers and one for health plans. For health
plans, the posting provides a text version of the model notice, as well as versions in other formats.
The National Legal & Research Group is reviewing the model notices and will provide details on
them in a future publication.
Background
The final HIPAA Privacy Rules (issued January 25, 2013) materially changed the required content
of the notice of HIPAA privacy practices that covered entities (including health plans) are required
to provide. As a result of the changes, self-insured employer-sponsored group health plans must
redistribute their notices of privacy practices by taking the following steps:
If the plan maintains a website including benefits information, the revised notice of privacy
practices must be posted on the website by September 23, 2013.
The notice of privacy practices must also be delivered to individuals. This delivery can be
made by email (if the individual has agreed to receive electronic distribution of such
notices) or the notice may be mailed (first class mail) or it may be delivered by
hand. Delivery of the notice does not require a special mailing, and the plan may choose to
include the notice with annual enrollment materials. NOTE: If the plan does not have a
website with benefits information, then the revised notice must be distributed within 60
days of the material revision.
Guidance on Applying Health Care Reform to HRAs, Health FSAs, EAPs and Certain Other
Arrangements
Under new guidance, it appears that stand-alone health reimbursement arrangements (HRAs)
providing benefits to anyone other than retirees are no longer viable. That is, in order for an
HRA to be exempt from certain health care reform requirements (which they generally
2. cannot meet), HRAs must be "integrated" with group health plan coverage. Integration
requires meeting several restrictive conditions. The guidance also addresses health FSAs,
employee assistance programs (EAPs), and arrangements under which employers pay or reimburse
premiums for individual health coverage or make a specified amount available for that purpose.
Background
The health care reform law prohibits group health plans from having annual dollar limits on
benefits. HRAs are group health plans and, almost by definition, they have annual dollar
limits. Under an HRA, an employer makes a specified amount available to each employee in order
to reimburse qualifying medical expenses, which may include certain health insurance premiums.
In previous guidance, federal agencies clarified that HRAs which are integrated with major
medical coverage will be considered to comply with the health care reform law's prohibition of
annual limits (see Willis Human Capital Practice Alert, July 2010, "Patient's Bill of Rights
Guidance Issued"). Since then, the agencies have provided guidance on what it means for an HRA
to be integrated with a major medical program, and the extent to which other HRAs (stand-
alone HRAs) can avoid violating the prohibition of annual dollar limits (see Willis HR Focus,
Issue # 69, March 2013, "Agencies Release More Health Care Reform FAQs," section on
HRAs). The agencies have also previously confirmed that excepted benefits -- those benefits that
meet the requirements for exemption from the HIPAA portability requirements -- are not subject to
the coverage reforms included in the health care reform law, including the prohibition of annual
dollar limits on benefits and the requirement to provide preventive care with no cost sharing (an
explanation of excepted benefits can be found in Willis’ Human Capital Practice Alert, July 2011,
“Looking Ahead - Compliance After 2011,” and a recent clarification is explained in Willis HR
Focus, Issue # 69, March 2013, "Agencies Release More Health Care Reform FAQs," section on
indemnity plans).
New Guidance
The new guidance apparently is intended to coordinate previous piecemeal guidance and to fill in
gaps. The National Legal & Research Group is reviewing the guidance and will provide additional
details in future publication(s). Some highlights from the guidance include:
It appears that any HRA, other than a retiree-only HRA, must be integrated with a group
health plan in order to avoid violating the health care reform law's prohibition of annual
limits.
The guidance sets out two alternative multi-part tests for determining whether an HRA is
considered integrated with non-HRA group health coverage. While the tests allow for
3. additional situations to be considered integration, in the case of a typical employer-
sponsored HRA/major medical program, integration would exist if:
o The major medical portion of the coverage is considered to have at least 60%
actuarial value (it is unclear whether it must also be affordable for this purpose)
o The HRA is available only to employees who are enrolled in the major medical
coverage
o Each employee covered by the HRA is actually enrolled in the major medical
coverage
o The HRA allows each participant to permanently opt out of the HRA and waive
future reimbursements from the HRA at least annually and, upon termination of
employment, either any remaining balance is forfeited or the participant is
permitted to permanently opt out of the HRA and waive future reimbursements (the
guidance explains that this condition is necessary because HRA coverage is
minimum essential coverage and continuing availability of reimbursements would
preclude qualifying for premium assistance in connection with coverage obtained
through a health insurance exchange)
An HRA generally cannot be considered to be a health FSA for purposes of the exemption
from the annual dollar limits prohibition that applies to health FSAs.
Any arrangement under which an employer pays, or makes amounts available to pay or
reimburse, the cost of health coverage on a tax-favored basis is considered a group health
plan that must comply with the coverage reform provisions of the health care reform law,
including the prohibition of annual dollar limits on benefits and the requirement that non-
grandfathered plans cover certain preventive services with no cost-sharing requirements.
If an employer pays or reimburses health insurance premiums (including premiums for
individual health insurance) on an after-tax basis, that arrangement will not be considered
to be a group health plan that is subject to coverage reforms.
The agencies intend to modify previously issued regulations defining excepted benefits to
provide that EAP coverage is an excepted benefit (i.e., exempt from the coverage reforms)
so long as the EAP does not provide significant benefits in the nature of medical care or
treatment.
The new agency guidance applies for plan years beginning on and after January 1, 2014, but may
be applied for all prior periods.
The information in this publication is not intended as legal or tax advice and has been prepared
solely for informational purposes. You may wish to consult your attorney or tax adviser
regarding issues raised in this publication.