Employee Benefits Blog

Agencies Come Down Hard on Various Employer Health Plans and Arrangements

As we move into 2015, employers continue to grapple with numerous Health Care Reform concepts. Employers should be cautious regarding arrangements promoted to avoid health care penalties because the agencies are cracking down, as shown below. On November 4, 2014, the IRS and other agencies indicated that they have become aware that group health plans […]

November 13, 2014 | 2 min read | Tagged: Health Care, health care reform, HRAs, in-patient hospitalization, IRS, minimum essential coverage, minimum value coverage, skinny plans

Nancy K. Campbell Of Counsel

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 […]

March 19, 2014 | 3 min read | Tagged: Affordable Care Act, Health Care, health care reform, health plans, health reimbursement arrangements, HRAs

Nancy K. Campbell Of Counsel