Human Resources
So Complex It’s Scary: Friday the 13th Affordable Care Act Guidance on HRAs, Health FSAs, and EAPs

So Complex It’s Scary: Friday the 13th Affordable Care Act Guidance on HRAs, Health FSAs, and EAPs


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The Department of Labor (DOL), Treasury, and Health and Human Services (HHS) (the agencies) issued technical guidance on Friday, September 13, 2013 that clarified the application of the Patient Protection and Affordable Care Act’s (Affordable Care Act’s) group market reforms to health reimbursement arrangements (HRAs), employer payment plans, health flexible spending accounts (health FSAs), and employee assistance plans (EAPs). The guidance focused, in particular, on the application of the rules prohibiting annual dollar limits on essential health benefits (EHBs) and prohibiting cost sharing for certain preventive health services on an in-network basis.

The guidance—DOL Technical Release 2013-03 and Internal Revenue Service (IRS) Notice 2013-54—applies to plan years beginning on and after January 1, 2014, but the guidance can also be applied for all prior periods. This Aon Hewitt bulletin discusses the impact of this guidance on employer-provided health care plans.

Download So Complex It’s Scary: Friday the 13th Affordable Care Act Guidance on HRAs, Health FSAs, and EAPs