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Small Employer Standalone HRA Allowed by New Law
Dickinson Wright PLLC Link to more items from this source
[Guidance Overview]
Dec. 12, 2016

"An employer offering a Qualified HRA must provide each eligible employee a written notice at least 90 days before the beginning of the year including: [1] The amount of the permitted benefit under the Qualified HRA for the year; [2] A statement that if the employee is applying for advance payment of the premium tax credit for health insurance on the Marketplace, the employee must inform the Marketplace of the amount of the permitted benefit under the Qualified HRA; [3] A statement that if the employee is not covered under minimum essential coverage for any month, the employee may be subject to a tax under Code Section 5000A and reimbursements under the Qualified HRA may be taxable income. Under a transition rule, for 2017, the notice must be provided within 90 days after the date of enactment of the new law."

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