Non-integrated health reimbursement arrangements (whatever they are called) are subject to $36,500 per-participant per-year penalty
Last fall the IRS and DOL issued nearly identical guidance, IRS Notice 2013-54 and DOL Technical Release 2013-03, explaining how certain Health Care Reform Act rules apply to health reimbursement arrangements (“HRAs”). Notice 2013-54 is not good news for most HRAs, also called medical expense reimbursement plans (“MERPs”). Executive physical plans are often structured as […]
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3 min read
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Tagged: Affordable Care Act, Health Care, health care reform, health plans, health reimbursement arrangements, HRAs
Nancy K. Campbell
Of Counsel