"Based on the draft instructions the agency had issued earlier in the summer, employers were worried there would be additional reporting obligations for HRA plan sponsors with fully insured health plans. However, in the [final instructions] the agency laid those concerns to rest. According to the IRS, employers with fully insured plans with an HRA that have employees enrolled in both plans aren't required to report the cover under the HRA. This is also true for firms with self-insured plans with HRAs."