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Application of the ACA to HRAs and FSAs
Thompson Coburn Link to more items from this source
[Guidance Overview]
Sept. 4, 2014
"[IRS Notice 2013-54] limits the ability of employers to set up HRAs, health FSAs, and other stand-alone employer payment plans for employees to use to purchase coverage on the individual market.... Since this new guidance clarifies that these arrangements cannot be integrated with coverage purchased on the individual market, any stand-alone HRA, health FSA not limited to excepted benefits, or other employer payment plan described in the Notice will fail to comply with the annual dollar limit prohibition and the preventative services requirement of the ACA market reforms."

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