Executive Order 13813 takes a new approach to employer interaction with individual policy reimbursement.  This is another shot at the Affordable Care Act and following regulations, some of which, like the allowance for individual plan reimbursement, had been tax policy for over 50 years.  Now the allowance is back, albeit with a set of complex restrictions

  1. Permits Health Reimbursement Accounts to be integrated with individual plans
    • Employees who case to be covered by the policy must forfeit the HRA
    • Employer can divide employees into separate classes for HRA or group plan
    • These classes include full time, part time, seasonal, CBA covered, under age 26
    • Pre Tax contributions allowed but not for subsidized exchange premium
    • HRA must be offered on the same terms to all members in a particular class
    • Verification and substantiation of the individual plan must be providedThe individual plan must provide medical and not just associated health benefits
    • No class of employees may be offered both an HRA integrating with both group and individual coverage
  2. Employees have the ability to opt out of the HRA to keep eligibility on the Exchange
  3. HRA for health related items not related to individual plans is limited to $1,800
  4. ACA would continue to treat the HRA as an employer sponsored plan

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