ACA FAQ Part 37 Addresses HRAs, Interpretation of "Health Insurance Coverage"

The Departments of Labor (DOL), Health and Human Services (HHS), and the Treasury released Affordable Care Act (ACA) Implementation Frequently Asked Questions (FAQs) Part 37 discussing four specific questions related to health reimbursement arrangements (HRAs) and interpretation of "health insurance coverage".

The four questions address:

  • Integration of HRAs with group health plans sponsored by the employer of a spouse of an employee; and
  • Coordinated and Consistent Interpretation of "Health Insurance Coverage"

Other included discussions relate to:

  • HRAs and employer payment plans;
  • Code Section 162(m)(6) ;
  • Application of Code Section 162(m)(6) to Certain Clinical Risk-Bearing Entities; and
  • Medical Loss Ratio (MLR) Guidance Provided in CCIO Technical Guidance 2012-002