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When Does ERISA Apply to HSAs? (PDF)
The Wagner Law GroupLink to more items from this source
[Guidance Overview]
Jan. 8, 2015
"In general, according to the [DOL], HSAs are not viewed as 'welfare benefit plans' subject to [ERISA]. However ... this exemption is contingent on the employer's limited involvement with the HSA, and advisers assisting employers with HSA arrangements need to be aware of such limitations."

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