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Agencies Respond to Trump Order, Issue Proposed Regs Paving Way for More HRAs
McDermott Will & Emery 
[Guidance Overview] Nov. 1, 2018
"The proposed 'Integrated HRA' rules would permit employers of any size to offer a standalone HRA to employees and former employees who have individual health coverage.... As an alternative to the Integrated HRA option, the Proposed Rule would recognize certain HRAs as limited excepted benefits (Excepted Benefit HRA). An Excepted Benefit HRA would allow participants to obtain reimbursement for certain qualified expenses even if they choose not to enroll in an employer's group health plan coverage."
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