Health Affairs Source Article | Comments Courtesy of Matt Zavadsky

This is a very comprehensive, (i.e.: long) interpretation of the new HRA regulations. 

Seems that these changes could have significant impact on both employers and employees.

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Final Rule On Health Reimbursement Arrangements Could Shake Up Markets

Katie Keith

JUNE 14, 2019

On June 13, 2019, the Departments of Health and Human Services, Labor, and Treasury issued a new final rule to expand the use of health reimbursement arrangements (HRAs) by employers to fund premiums for their employees in the individual health insurance market. The final rule reverses prior federal guidance by allowing HRAs to be used to fund both premiums and out-of-pocket costs associated with individual health insurance coverage. The Departments also released new frequently asked questions, model attestations, and model notices.

The final rule is largely similar to the proposed rule, which received more than 500 comments from a stakeholders that include state regulators, insurers, and employers, brokers, and benefit advisors. The final rule’s major significant changes focus primarily on new “integration requirements” for HRAs. The rule also allows a new “excepted benefit HRA” option that employees can use to pay premiums for excepted benefits and short-term coverage. Individuals who gain access to an HRA or qualified small employer health reimbursement arrangement are eligible for a special enrollment period in the individual market.

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