Additional Guidance on Health Care Reform Pertaining To HRAs

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.

Additional Guidance on HRAs

 DOL FAQs about Affordable Care Act Implementation Part XI

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The information provided is for informational purposes only and does not constitute legal advice. The information above contains only a summary of the applicable legal provisions and does not purport to cover every aspect of any particular law, regulation or requirement. Depending on the specific facts of any situation, there may be additional or different requirements. This is to be used only as a guide and not as a definitive description of your compliance obligations.