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ECFC Comment Letter to IRS on about Qualified Small Employer Health Reimbursement Arrangements (PDF)
Employers Council on Flexible Compensation [ECFC] 
[Opinion] Jan. 16, 2018
"We believe that Congress did not intend that coverage of excepted benefits would be considered group health coverage causing an employer to be unable to offer a QSEHRA to its employees.... [IRS Notice 2017-67 provides] that an employer would not be eligible to offer a QSEHRA if it provides current employees with continued access to amounts which accumulated in an HRA in previous year or carryover amounts in an FSA ... This is counterproductive to the policy behind consumer-directed health accounts[.]"
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