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IRS Begins Discussing HRAs, the ACA Employer Mandate, and Nondiscrimination
HUB International Link to more items from this source
[Guidance Overview]
Dec. 5, 2018
"The new proposed rules allowing employers to reimburse for individual insurance policies ... included some options that could, or would, violate existing nondiscrimination rules that apply to [HRAs] and other self-insured health plans. The IRS is now starting to address those concerns with the release of Notice 2018-88.... [T]he Notice is just an expression of where the IRS expects to go. While it is a helpful breadcrumb in that process, employers cannot start implementing this now."

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