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New Individual Coverage and Excepted Benefit HRAs: DOL Guidance and Compliance Challenges for Employers

Notice and Claim Administration Requirements, Impact of New Design on Employees, Interaction With ACA and ERISA

Recording of a 90-minute premium CLE webinar with Q&A

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Conducted on Wednesday, January 29, 2020

Recorded event now available

or call 1-800-926-7926

This CLE course will guide ERISA counsel and employers through the numerous and complex rules with reference to the most recent Tri-Agency guidance. The panel will discuss the recent expansion of HRAs and rules for developing and implementing the new plan designs for employers, notice and claim administration requirements, the interaction of individual HRAs with ACA and ERISA, the impact to employees, and best practices to overcome compliance challenges in light of the new rules.


On June 13, 2019, the Departments of Labor, Treasury, and Health and Human Services (the “Tri-Agencies”) issued final regulations regarding health reimbursement arrangements (HRAs). Effective for plan years beginning on and after January 1, 2020, the new rules allow employers to integrate HRAs with health insurance coverage purchased on the individual market and with Medicare (individual coverage HRAs or “ICHRAs) so long as they implement strict plan design mechanisms and administrative procedures. The final rules also allow sponsors to establish nonintegrated general-purpose excepted benefit HRAs (“EBHRAs”).

HRAs are account-based health plans funded with employer contributions to reimburse eligible participants and dependents for medical expenses. Under the new rules, employers can use ICHRAs to provide employees and their spouses and tax dependents with tax-preferred funds to pay for the cost of health insurance coverage purchased on the individual market subject to certain conditions.

The rules also create a new type of excepted-benefit HRAs, which lets employers that offer traditional group health plans provide a general-purpose HRA with limited annual amounts even if the worker doesn't enroll in the traditional group plan.

ERISA counsel and employers must understand the requirements for designing and implementing the new HRAs and avoid compliance pitfalls under the new rules.

Listen as our panel provides an in-depth analysis of the final rules on HRAs, critical considerations for plan design, and notice and claim administration challenges, as well as offers best practices to ensure compliance.



  1. Background and overview of HRAs and ERISA implications
  2. ICHRAs
  3. Excepted benefit HRA
  4. Best practices for ensuring compliance in the admistration of HRAs


The panel will review these and other vital issues:

  • Key takeaways from the final rules and recent Tri-Agency guidance on HRAs
  • ERISA implications of HRAs and critical compliance issues
  • Integration of HRAs with ACA-compliant coverage
  • ICHRA design and eligibility requirements
  • Notice and substantiation requirements of ICHRAs
  • The impact of the premium tax credit and employer mandate on ICHRAs
  • Excepted benefit HRAs and maintaining excepted benefit status


Marrapese, Art
Arthur A. Marrapese, III

Barclay Damon

For over 30 years, Mr. Marrapese has helped plan sponsors, and fiduciaries identify, prioritize, and minimize the...  |  Read More

Watson, Roberta
Roberta Casper Watson

The Wagner Law Group

Ms. Watson focuses on ERISA and employee benefits. She concentrates on a wide array of areas including, pension and...  |  Read More

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