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Addressing Employee Health Plan Exception Requests: Requests for Employer to Reimburse Outside the Plan
Newfront 
[Guidance Overview] Sept. 9, 2022 "Reimbursement of Internal Revenue Code Section 213(d) health expenses creates a group health plan, which would trigger the full array of group health plan laws (ERISA, COBRA, HIPAA, ACA, HSA eligibility, Section 105(h), etc.). Therefore, employers should avoid providing reimbursement for any Section 213(d) medical expenses outside of the group health plan unless it is part a HRA or wellness program that is integrated with the health plan." |
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