The Departments of Health and Human Services, Treasury and Labor delivered the third and final proposed rule to expand Health Reimbursement Arrangements (HRA).
The rule intends to simultaneously provide employers with a variety of options when offering health benefits to their employees and offer employees with greater opportunity to select the coverage they desire. Annette Bechtold, Senior Vice President of Regulatory Affairs and Reform Initiatives for OneDigital, explains in detail the various restrictions the ACA’s market rules have imposed on the use of HRAs in a benefits program. She details the restrictions in the article she authored “HRA Expansion: An In-Depth Look at the Proposed Rule” published in National Association of Health Underwriters (NAHU’s) Compliance Cornered Blog, including HRA integration requirements, excepted benefits, premium tax credits, interactions with ERISA, and many more. Due to the high volume of questions and requests submitted to the Departments, this new rule would not be applicable until on or after January 1, 2020.
This new rule provides an interesting alternative to traditional health benefits. Its feasibility and attractiveness to employers is contingent on any modification in the final rules and the particular circumstance of the individual employer and the individual state marketplace coverage cost and availability. Until the Departments receive all the comments, review them and address them in the next version of this regulation, this option remains unavailable.
— Annette Bechtold, SVP, Regulatory Affairs and Reform Initiatives, OneDigital
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To stay updated on the department’s final proposed rule, HRAs impact on health benefit programs and all ACA reforms and requirements reach out to your OneDigital consultant.