Health Reimbursement Account Design and Compliance

Summary

This practice note discusses how to design and operate compliant employer-sponsored health reimbursement accounts (HRAs), including compliance considerations under the Internal Revenue Code (Code), the Employee Retirement Income Security Act of 1974 (ERISA), the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA), the Health Insurance Portability and Accountability Act (HIPAA), and with a particular focus on the Patient Protection and Affordable Care Act (ACA). Also covered are new rules allowing employers to offer so-called individual coverage HRAs (ICHRAs) and excepted benefit HRAs (EBHRAs) beginning on and after January 1, 2020.