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Defined Benefit Combo Cash Balance Compliance Consultant Loren D. Stark Company (LDSCO)
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IRS Proposes Revisions to ACA Reporting for Health Reimbursement Arrangements
E is for ERISA [Guidance Overview] Sept. 18, 2015 "The proposed new anti-duplication rules, which will apply month-by-month and individual-by-individual, will provide that if an individual is covered by multiple MEC plans or programs provided by the same provider, reporting is required for only one of them.... [If] an individual is enrolled in a self-insured group health plan for a given month and also is takes part in an HRA sponsored by the same employer, the employer ... is required to report only one type of coverage for that individual (which most likely would be the self-insured group health plan) for that month.... Under the second proposed anti-duplication rule, reporting generally is not required for MEC for which an individual is eligible only if the individual is covered by other MEC for which MEC reporting is required, so long as the two types of coverage are sponsored by the same employer." |
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