ACA FAQ 37 Clarifies HRA Rules

The Departments of Labor, the Treasury, and Health and Human Services (collectively, the Departments) released Affordable Care Act (ACA) FAQ 37 last week, providing further clarification as to how a “family HRA” (health reimbursement arrangement) can reimburse expenses of family members and remain integrated with group health plan coverage.

Specifically:

  • The guidance clarifies that expenses of family members can be reimbursed through a family HRA as long as every family member has coverage through a group health plan and the HRA meets integration requirements.
  • If an employee has group health plan coverage and an integrated HRA, the expenses of a spouse or children cannot be reimbursed through the HRA if the spouse or children are uninsured or have individual health insurance policies.

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