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New Individual Coverage and Excepted Benefit HRAs: DOL Guidance and Compliance Challenges for Employers


Jan. 29, 2020
Recorded Online

Notice and Claim Administration Requirements, Impact of New Design on Employees, Interaction With ACA and ERISA

This CLE webinar will guide ERISA counsel and employers on new individual coverage and excepted benefit health reimbursement arrangements (HRAs) and recent DOL guidance. The panel will discuss the recent expansion of HRAs and rules for developing and implementing the new plan designs for employers, notice and claim administration requirements, the interaction of individual HRAs with ACA and ERISA, the impact to employees, and best practices to overcome compliance challenges in light of the new rules.

On June 13, 2019, the Departments of Labor and Health and Human Services issued final regulations regarding HRAs. Effective as of Jan. 1, 2020, the new rules allow employers to combine HRAs with health insurance so long as they implement strict plan design mechanisms and administrative procedures.

HRAs are account-based health plans funded with employer contributions to reimburse eligible participants and dependents for medical expenses. Under the new rules, employers can use individual coverage health reimbursement accounts (ICHRAs) to provide workers with tax-preferred funds to pay for the cost of health insurance coverage subject to certain conditions.

The rules also create excepted-benefit HRAs, which lets employers that offer traditional group health plans provide an excepted-benefit HRA with limited annual amounts even if the worker doesn't enroll in the traditional group plan.

ERISA counsel and employers must understand the requirements for designing and implementing health reimbursement arrangements and avoid compliance pitfalls under the new rules.

Listen as our panel provides an in-depth analysis of the final rules on HRAs, critical considerations for plan design, and notice and claim administration challenges, as well as offers best practices to ensure compliance.


  • Background and overview of HRAs and ERISA implications
  • ICHRAs
  • Excepted benefit HRA
  • Best practices for ensuring compliance in the admistration of HRAs

The panel will review there and other vital issues:

  • Key takeaways from DOL and IRS final rules on HRAs
  • ERISA implications of HRAs and critical compliance issues
  • Integration of HRAs with ACA-compliant coverage
  • ICHRA design and eligibility requirements
  • Notice and substantiation requirements of ICHRAs
  • The impact of the premium tax credit and employer mandate on ICHRAs
  • Excepted benefit HRAs and maintaining excepted benefit status


  • Arthur A. Marrapese, III, Partner, Barclay Damon
  • Roberta Casper Watson, Partner, The Wagner Law Group

More Information, How to Register

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