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Health Care Reform: IRS Issues FAQs on Various ACA Issues

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January 2013

The IRS issued another set of FAQs that covers various topics of interest under the Affordable Care Act. This set of FAQs provides, among other things, that the employer-provided notice of available exchange-based coverage does not need to be provided by the initial March 1, 2013 deadline (a new deadline has not been set but is expected be late summer or fall of 2013); that health reimbursement arrangements (HRAs) will generally not comply with the ACA’s prohibition on lifetime and annual limits unless the HRA is “integrated” with an employer’s group health plan; and that multiemployer welfare plans can use plan assets to pay the ACA’s annual “PCORI” fee.

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