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Private Health Insurance Exchanges: Tax and ERISA Issues (PDF)
Sutherland Asbill & Brennan LLP Link to more items from this source
Apr. 22, 2014
9 pages. Excerpt: "Private exchanges are largely unregulated as an entity, raising persistent concerns regarding the potential application of ERISA and tax rules for health plans.... [N]ew complexity surrounding the use of HRAs to fund employer-sponsored plans has caused private exchange sponsors to reevaluate the use of HRAs as a vehicle for funding employer premium subsidies. Although it appears that current HRA integration rules should apply to coverage offered on a private exchange, the guidance to date has not addressed the use of HRAs alongside private exchange coverage, and the path to full compliance remains unclear."

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