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Are HSA Contribution Programs Ever Subject to ERISA? (PDF)
Thomson Reuters / EBIA 
[Guidance Overview] Feb. 22, 2024 "HSAs are viewed as personal accounts that are not ERISA-covered welfare benefit plans, so long as employee participation is completely voluntary and the employer's involvement is limited. However, there are ways in which an HSA contribution program could become subject to ERISA. Those ERISA triggers should be avoided because ERISA's compliance obligations were not crafted with HSAs in mind, and it is not clear how and whether all of ERISA's requirements could be satisfied by an HSA program." MORE >> |
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