Well, let's hope for the best with the new rules.
This AICPA article does not offer much clarity.
https://www.journalofaccountancy.com/ne ... 21481.html
This language indicates Medicare reimbursements have been OK. How did I miss that? Or had this been wiped out under those $100 per day penalty rules and it will be OK again?
Q&A-3 of Notice 2015-17 also provided that an employer payment plan through which
an employer reimburses (or pays directly) all or a portion of Medicare Part B or D premiums for
employees may not be integrated with Medicare coverage to comply with PHS Act sections 2711
and 2713 because Medicare coverage is not a group health plan. However, under the notice, this
type of employer payment plan may be integrated with another group health plan offered by the
employer for purposes of PHS Act sections 2711 and 2713 if: (1) the employer offers a group
health plan (other than the employer payment plan) to the employee that does not consist solely
of excepted benefits
Anyhow, I am clearly clueless just hoping for good news on the HRA front.
Here the new reg is: https://s3.amazonaws.com/public-inspect ... -12571.pdf
Final Regulations Permit Integration of HRAs with Individual Health Insurance Coverage: The IRS, Department of Labor, and Department of Health and Human Services have issued final regulations that permit the integration of Health Reimbursement Arrangements (HRAs) and other account-based group health plans with individual health insurance coverage or Medicare, if certain conditions are met (an individual coverage HRA ). The final regulations also provide conditions under which certain HRAs and other account-based group health plans will be recognized as limited excepted benefits . In addition, the agencies are finalizing rules on (1) premium tax credit eligibility for individuals offered an individual coverage HRA; (2) safe harbor conditions that prevent premiums reimbursed by an individual coverage HRA or a Qualified Small Employer Health Reimbursement Arrangement (QSEHRA) from becoming part of an ERISA plan; and (3) a special enrollment period in the individual market for those gaining access to an HRA or QSEHRA. The regulations, which are effective on 8/19/19, generally apply for plan years beginning on or after 1/1/20. TD 9867.