Guidance Issued Regarding Qualified Small Employer Health Reimbursement Arrangements Established


Yesterday, the agencies involved in the implementation of the Affordable Care Act (The Departments of Labor, Health and Human Services and the Treasury) released additional Frequently Asked Questions (FAQs) regarding the implementation of the ACA.  Read aca-part-35.pdf here.  One section of this FAQ addresses the new Qualified Small Employer Health Reimbursement Arrangements (QSBHRAs) established under the recently enacted 21st Century Cures Act.  The FAQ provides limited guidance on QSBHRA and focuses on the transition rules provided under IRS Notice 2015-17 and the continued application of the market reform rules for health reimbursement arrangements that are not considered QSBHRAs. 

While guidance is always helpful, there is still many issues regarding QSBHRAs that will need to be addressed in agency guidance.  ECFC will be preparing a letter to the agencies outlining the issues that we believe need to be addressed regarding this new arrangement.

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Martin Trussell
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About Employers Council on Flexible Compensation

The Employers Council on Flexible Compensation (ECFC) is a non-profit organization dedicated to the maintenance and expansion of private employee benefit programs on a tax-advantaged basis. The organization has two driving missions. The first is to represent and promote flexible compensation programs through effective lobbying. The second is to provide information on flexible compensation programs to member, national opinion leaders and the general public to help create a positive climate for the growth of flexible compensation.