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The Future of HRAs: Plan Designs and Pragmatic Questions (PDF)
Kushner & Company Link to more items from this source
[Guidance Overview]
Oct. 7, 2013

"We want to provide an HRA to employees who have comprehensive group health coverage elsewhere. Is this still allowed? ... [An] 'integrated' health plan can be at the employer or at another employer (such as a spouse's employer's qualifying group health plan). This will likely require a signed certification and/or proof of the other comprehensive coverage ... Can we use our HRA to reimburse individual insurance premiums on the public Exchange/Marketplace? ... the new guidance specifically excludes these arrangements .... What is allowed is a similar approach through a private exchange."

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