The Departments of Labor, Health and Human Services, and the Treasury have recently issued guidance, in the form of FAQs, addressing the confusion surrounding HRA’s and the Affordable Care Act (“ACA” or “Health Care Reform”).
One of the major components of the Affordable Care Act (“ACA” or “Health Care Reform”) is the prohibition on imposing any annual or lifetime limits on essential health benefits. For quite some time, there has been some confusion about how Health Reimbursement Arrangements (“HRAs”) would interact with this prohibition. By their very nature, HRAs impose limits on reimbursements.