HRA Final Rules Released

Final Rules have been released by the Departments of Labor, Treasury, and Health and Human Services lifting the ban on pairing HRAs with individual health policies.

The Final Rules also “allow certain HRAs and other account-based group health plans to qualify as limited excepted benefits”.

According to JD Supra, Excepted Benefit HRAs must meet the following requirements to satisfy the Final Rules:

  • Otherwise not an integral part of the plan.
  • Limited in amount.
  • Prohibition on reimbursement of premiums for certain types of coverage.
  • Uniform availability.

The Final Rules are “generally effective” for plan years beginning on or after January 1, 2020.

To learn more about ICHRAs and the rules surrounding them, please click here.


The information included in this blog post originally appeared in an article from JD Supra on July 30, 2019 written by Megan Mardy, Jacob Mattison, Emily Rickard, and Judith Wethall of McDermott Will & Emery.

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