New Individual Coverage & Excepted Benefit HRAs | CLE Course

BarbriSFCourseDetails

Course Details

Course Information

smart_display Format
On-Demand
signal_cellular_alt Difficulty Level
work Practice Area
ERISA

Date & Time

event Date
Wednesday, January 29, 2020
schedule Time
1:00 p.m. ET./10:00 a.m. PT
timer Program Length
90 minutes

Credit Information

This 90-minute webinar is eligible in most states for 1.5 CLE credits.

$297.00

CLE

ALL

This CLE course will guide ERISA counsel and employers through the numerous and complex rules with reference to the most recent Tri-Agency guidance. The panel will discuss the recent expansion of HRAs and rules for developing and implementing the new plan designs for employers, notice and claim administration requirements, the interaction of individual HRAs with ACA and ERISA, the impact to employees, and best practices to overcome compliance challenges in light of the new rules.

Faculty

Roberta Casper Watson

Partner

The Wagner Law Group, LLP

Ms. Watson focuses on ERISA and employee benefits. She concentrates on a wide array of areas including, pension and profit sharing plans, health and welfare benefit plans, including COBRA, HIPAA and the Affordable Care Act, ERISA fiduciary decision-making, Employee Stock Ownership Plans, benefits litigation backup, benefits aspects of mergers and acquisitions, employee benefits aspects of family law, labor laws affecting employee benefits, other employee benefits and deferred Compensation, and employee benefit disputes and employee benefits claims.

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Arthur A. Marrapese

Partner

Barclay Damon

For over 30 years, Mr. Marrapese has helped plan sponsors, and fiduciaries identify, prioritize, and minimize the litigation and liability risks associated with the management and administration of employee benefit programs through plan drafting, employee communications strategies, plan governance ideas, and best practice policies and procedures. He has experience drafting employee benefit plan documents and summary plan descriptions and assists senior executive and board members in understanding their fiduciary responsibilities related to plan governance and taking steps to minimize those responsibilities and the attendant litigation and liability risks.

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Description

On June 13, 2019, the Departments of Labor, Treasury, and Health and Human Services (the “Tri-Agencies”) issued final regulations regarding health reimbursement arrangements (HRAs). Effective for plan years beginning on and after January 1, 2020, the new rules allow employers to integrate HRAs with health insurance coverage purchased on the individual market and with Medicare (individual coverage HRAs or “ICHRAs) so long as they implement strict plan design mechanisms and administrative procedures. The final rules also allow sponsors to establish nonintegrated general-purpose excepted benefit HRAs (“EBHRAs”).

HRAs are account-based health plans funded with employer contributions to reimburse eligible participants and dependents for medical expenses. Under the new rules, employers can use ICHRAs to provide employees and their spouses and tax dependents with tax-preferred funds to pay for the cost of health insurance coverage purchased on the individual market subject to certain conditions.

The rules also create a new type of excepted-benefit HRAs, which lets employers that offer traditional group health plans provide a general-purpose HRA with limited annual amounts even if the worker doesn't enroll in the traditional group plan.

ERISA counsel and employers must understand the requirements for designing and implementing the new HRAs and avoid compliance pitfalls under the new rules.

Listen as our panel provides an in-depth analysis of the final rules on HRAs, critical considerations for plan design, and notice and claim administration challenges, as well as offers best practices to ensure compliance.