FINAL HRA RULES PERMIT INTEGRATION

Final HRA rules permit integration. The Department of the Treasury, Labor, and Health and Human Services jointly issued final regulations governing health reimbursement arrangements. The Final regulations allow integration of HRA’s with individual health insurance coverage, if certain conditions are satisfied. The rules also allow certain HRA’s to be recognized as excepted benefits. HRA’s are generally account based groups health plans funded solely by employer contributions that reimburse employees for health care costs. Final HRA rules permit integration.

The Departments noted that the regulations were being issued to increase the usability of HRAs, to expand employers ability to offer HRAs to their employees, and to allow HRAs to be used in conjunction with nongroup health insurance coverage (generally coverage on the individual market). The rules remove the prohibition on integrating an HRA with individual health insurance coverage, if certain conditions are met, and contain requirements that an HRA must meet to be integrated with individual health insurance coverage. The final rules denote these plans as “individual coverage HRAs.” The Departments are concerned that allowing HRAs to be used may result in employers encouraging higher risk employers who have higher expected medical claims to obtain insurance on the health insurance exchange for individual health coverage, which cold destabilize the individual health insurance marketplace by steering more high risk people into it.

Therefore, the final rules prevent a plan sponsor from steering any participants or dependents with adverse health factors away from the plan sponsor’s traditional group health plan and into the individual market, either intentionally or unintentionally, and indirectly or indirectly. That is, the rules for integrating HRAs prohibit a plan sponsor from offering the same class of employees both a traditional group plan and an HRA integrated with individual health insurance coverage. In addition, to the extent a plan sponsor offers an HRA that is integrated with individual health insurance coverage to a class of employees, the integration rules require that the HRA be on the same terms to all employees. If you had unexpected medical bill leaving you unable to pay your IRS taxes, call this 35 year old Tax Resolution Company to see if you qualify for the IRS Fresh Start Program. Tax Resolution can get you back to where you need to be financially.