United Benefit Advisors Insight and Analysis Blog

Top 3 Frequently Asked Questions about Qualified Small Employer Health Reimbursement Arrangements

Posted by: Danielle Capilla    Nov 22, 2017 9:30:00 AM

On December 13, 2016, President Obama signed the 21st Century Cures Act (Cures Act) into law. The Cures Act provides a method for certain small employers to reimburse individual health coverage premiums up to a dollar limit through HRAs called "Qualified Small Employer Health Reimbursement Arrangements" (QSE HRAs). The provision went into effect on January 1, 2017. On October 31, 2017, the IRS released Notice 2017-67, providing guidance on the implementation and administration of QSE HRAs.

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Topics: health reimbursement arrangements, Affordable Care Act, 21st Century Cures Act, Qualified Small Employer HRA, QSE HRA

DOL Asks for MHPAEA Related Comments; Clarifies Eating Disorder Benefit Requirements

Posted by: Danielle Capilla    Jun 28, 2017 9:30:00 AM

Earlier this month, the Department of Labor (DOL) provided an informational FAQ relating to the Mental Health Parity and Addiction Equity Act (MHPAEA) and the 21st Century Cures Act (Cures Act). This is the DOL's 38th FAQ on implementing the Patient Protection and Affordable Care Act (ACA) provisions and related regulations. The DOL is requesting comments on a draft model form for participants to use to request information regarding nonquantitative treatment limitations, and confirms that benefits for eating disorders must comply with the MHPAEA. Comments are due by September 13, 2017.

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Topics: ACA, Affordable Care Act, Mental Health Parity and Addiction Act, mental health, 21st Century Cures Act

Qualified Small Employer Health Reimbursement Arrangements and ERISA

Posted by: Danielle Capilla    Jun 1, 2017 9:30:00 AM

Certain small employers have the option to reimburse individual health coverage premiums up to a dollar limit through Qualified Small Employer Health Reimbursement Arrangements (QSE HRAs) under the 21st Century Cures Act (Cures Act).

The Cures Act amends the Employee Retirement Income Security Act of 1974 (ERISA) to exclude QSE HRAs from the ERISA definition of group health plan; however, the Cures Act does not specifically exclude QSE HRAs from the rest of ERISA.

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Topics: health reimbursement arrangements, 21st Century Cures Act, Qualified Small Employer HRA, QSE HRA

FAQ on HIPAA Special Enrollment; QSE HRAs Released

Posted by: Danielle Capilla    Feb 8, 2017 9:53:35 AM

Recently, the Department of Labor (DOL), Department of Health and Human Services (HHS), and the Treasury (collectively, the Departments) issued FAQs About Affordable Care Act Implementation Part 35. The FAQ covers a new HIPAA special enrollment period, an update on women's preventive services that must be covered, and clarifying information on qualifying small employer health reimbursement arrangements (QSE HRAs).

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Topics: HIPAA, group health insurance, health reimbursement arrangements, HRA, Danielle Capilla, 21st Century Cures Act, Qualified Small Employer HRA, benefits enrollment, women's preventive services

Implications of the 21st Century Cures Act

Posted by: Danielle Capilla    Feb 1, 2017 9:30:00 PM

On December 13, 2016, former President Obama signed the 21st Century Cures Act into law. The Cures Act has numerous components, but employers should be aware of the impact the Act will have on the Mental Health Parity and Addiction Equity Act, as well as provisions that will impact how small employers can use health reimbursement arrangements (HRAs). There will also be new guidance for permitted uses and disclosures of protected health information (PHI) under the Health Insurance Portability and Accountability Act (HIPAA). We review the implications with HRAs below; for a discussion of all the implications, view UBA’s Compliance Advisor, “21st Century Cares Act”.

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Topics: ACA, premium subsidies, health reimbursement arrangements, HRA, Affordable Care Act, health care cost, 21st Century Cures Act, Qualified Small Employer HRA, insurance premium reimbursement