At Benefit Comply our attorneys and regulatory analysts have expertise in a broad range of benefit compliance issues. While we continue to support the mission of broadening the ICHRA marketplace through the ICHRA Alliance, we also know that the recently passed ARPA will significantly impact many of your businesses. We are conducting a free COBRA Subsidy Q&A Webinar…
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CMS Collecting ICHRA Case Studies CMS is interested in gathering case studies to understand the experiences of employers offering individual coverage health reimbursement arrangements (ICHRAs) to their employees, and we invite you to support our case study collection efforts. Attached to this article is an information collection form, which gives employer groups an opportunity to…
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Register for our next ICHRA Alliance Webinar on Contribution Strategies Tuesday March 16th at 2:00 central Employer contributions to an ICHRA pose unique challenges. ICHRA rules allow age based, and tiered, contributions but there are rules the employer must follow. The EEOC has also provided guidance on how the Age Discrimination in Employment Act (ADEA) applies…
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When the need for insurance distribution infrastructure became clear, Vericred Co-Founder and CEO, Michael Levin, combined forces with technology expert, Daniel Langevin, to build a powerful platform. Today, Vericred is the industry leader in building the infrastructure for the digital distribution and fulfillment of health insurance and employee benefits. Our team is across the United…
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This week the IRS released final regulations clarifying how an individual coverage HRA (ICHRA) must be designed to satisfy §4980H offer of coverage requirements, §§6055 and 6056 employer reporting requirements, and benefit nondiscrimination rules. The rules finalize what was set forth in the proposed regulations released late in 2019 with no significant changes. The final…
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The Equal Employment Opportunity Commission (EEOC) released an opinion letter clarifying what is permitted for employer contributions or funding of an individual coverage HRA (ICHRA) under the Age Discrimination in Employment Act (Act). The EEOC addressed two scenarios: (i) an ICHRA offering where the employer makes the same monthly dollar amount available to all ICHRA…
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2020 Employer Reporting The IRS made the final 2020 employer reporting forms and instructions available. The Form 1094-Cs are pretty much identical to last year. The Form 1095-Cs were modified slightly, primarily to facilitate reporting by employers who offered individual coverage HRAs (ICHRAs) in 2020. The minor changes for the Form 1095-C as follows: For…
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The Department of Health and Human Services has published a good employee introduction to ICHRAs. The 3-page piece titled How an Individual Coverage Health Reimbursement Arrangement (HRA) Offer Works is available here: https://marketplace.cms.gov/outreach-and-education/how-an-individual-coverage-hra-offer-works.pdf
DOL Announces Flexibility on Timing of Required ICHRA Notice Last Updated: September 11, 2020 On June 23, 2020, the Department of Labor (DOL) released “FAQs About Families First Coronavirus Response Act and Coronavirus Aid, Relief, and Economic Security Act Implementation Part 43” (the FAQs)[i]. In the FAQs, the DOL announced additional flexibility for employers offering…
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Are You Ready for the New ICHRA Rules? Now that the rules are out, the million dollar question is: are the new Individual Coverage HRAs (ICHRAs) going to gain traction with employers? (Yes, we have another new acronym to memorize – ICHRA). I think it is easy to assume that the ICHRA may not be a…
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