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New Final Regulations on HRAs: Key Considerations and Guidance for Employee Benefits Counsel

Individual Coverage and Excepted Benefit HRAs, Notice Requirements, Administrative Challenges

Recording of a 90-minute premium CLE webinar with Q&A

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Conducted on Tuesday, September 10, 2019

Recorded event now available

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This CLE course will guide ERISA counsel on the key terms and provisions of the recently issued final regulations on health reimbursement arrangements (HRAs). The panel will discuss new HRA options such as the Individual Coverage and Excepted Benefit HRAs, notice requirements and potential administrative challenges, and guidance and critical considerations for benefits counsel in the design and implementation of HRAs in light of the final regulations.

Description

New rules released by the Department of Labor, Health and Human Services, and the Treasury provide employers more flexibility and alternatives to traditional group health plan coverage. The final regulations on health reimbursement arrangements (HRAs) allow additional tax-favored HRA options for employers but they impose strict conditions and compliance requirements.

Before the enactment of the Patient Protection and Affordable Care Act (PPACA), HRAs paid or reimbursed employees for the cost of individual insurance premiums and certain health expenses. However, HRAs are subject to market reforms impacting coverages and dollar limits since they are considered to be "group health plans" under the PPACA, which essentially disallows the use of HRAs to reimburse employees for the cost of individual insurance coverage.

The final regulations modify the treatment of specific alternatives to traditional group medical coverage under the PPACA and create the Individual Coverage HRA and Excepted Benefit HRA as mechanisms to (1) reimburse premiums for individual insurance coverage, and (2) reimburse certain medical expenses even if the employee is not enrolled in health coverage.

Listen as our panel discusses key provisions and compliance pitfalls of the final regulations on HRAs, provides an in-depth analysis of the requirements challenges of Individual Coverage and Excepted Benefit HRAs, and offers best practices in the implementation and administration of HRAs.

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Outline

  1. Key considerations for HRA compliance
  2. New final HRA regulations and potential legal and compliance issues
  3. New HRA plan options and avoiding compliance traps
    1. Individual Coverage HRAs
    2. Excepted Benefit HRAs
  4. Implications on ERISA and PPACA's employer mandate and premium tax credit
  5. Best practices for ERISA counsel, employers, and administrators

Benefits

The panel will review these and other key issues:

  • Avoiding compliance issues in HRAs
  • Key provisions of the new final regulations on HRAs and potential challenges
  • Understanding the dynamics of an Individual Coverage HRA and Excepted Benefit HRA
  • Impact on ERISA and PPACA's employer mandate and tax credit
  • Best practices in the implementation and administration of HRAs

Faculty

Hitesman, Darcy
Darcy L. Hitesman
Attorney
HitesmanLaw

Ms. Hitesman has 25 years of experience as an Employee Benefits law attorney. Throughout her career, she has been...  |  Read More

Wold, Scott
Scott A. Wold
Atty
Hitesman & Wold

Mr. Wold practices exclusively in the areas of employee benefits and executive compensation.

 |  Read More

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