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New HRA Rules: What Employers Need to Know
Ogletree Deakins Link to more items from this source
[Guidance Overview]
July 18, 2019

"[Individual coverage HRAs (ICHRAs)] raise two separate questions about affordability under the ACA: Would these plans be 'affordable' coverage that would disqualify an employee who has been offered the coverage from receiving a premium tax credit? ... Would ICHRA coverage be 'affordable' for purposes of the ACA requirement that employers generally offer affordable coverage to at least 95 percent of their full-time employees, or risk a penalty under Code Section 4980H(b)?"

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