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IRS Issues New Guidance on QSEHRA Plans

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Three weeks ago, we told you about the executive order the President signed (in our blog post Executive Order Seeks to Expand Use of HRAs ). The order asked the Departments of Treasury, HHS and Labor to explore how they could allow more businesses to use Health Reimbursement Arrangements (HRAs). Today, the Internal Revenue Service (IRS) issued Notice 2017-67 .  This notice provides long awaited guidance on the qualified small employer health reimbursement arrangement (QSEHRA). The QSEHRA plan is a great small business alternative group coverage. The plan was welcomed when it was signed into law in 2017 and, it overturned guidance previously issued by the Internal Revenue Service and the Department of Labor that stated that HRAs violated the ACA’s market reforms, subjecting small employers to a penalty for providing such arrangements. In this post, we will cover the notice in detail. What it means moving forward and its impact on existing plans. The Notice Today’s 59-pag
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Can I have an HSA and a QSEHRA at the same time?

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Wrong Question... Yes, you can have an HSA and a QSEHRA at the same time but, what you really want to know is if you can make tax free contributions to a Health Savings Account (HSA) in the same tax year you were provided a QSEHRA. That is a bit more complicated, let's jump into it.  This article was prompted by IRS Notice 2017-67 which provided administrative and procedural guidance on the QSEHRA. The notice indicated a departure from the HRA compatibility requirements which call for a deductible on the HRA equal to the qualifying high deductible health plan (HDHP) deductible. According to the guidance, the QSEHRA is not permitted to impose a deductible therefore, may be disqualifying coverage for those provided the benefit by their employer. The determination comes down to what and whom is covered by the QSEHRA. Background Under section 223, individuals who have high deductible health plan (HDHP) coverage and no other disqualifying health coverage may contribute t
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Serving Faith Based Nonprofits

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Keeping up with legislation has been difficult on churches. Over the past two years I have had dozens and dozens of difficult conversations with clergy from small, local Churches who have been tearfully concerned about their health insurance. Most have faced a series of events that has pushed their ability to maintain adequate health coverage into a death spiral. Notices of a large premium increases, that they can not afford, combined with conflicting information regarding the ability of  Churches to contribute to clergy's health insurance premiums has created a crisis. In 2016, fewer than half of the solo pastors in the U.S. received any health insurance benefits. Many small businesses and practitioners I work with had not heard of an HRA prior to the 2013 IRS guidance that attempted to prohibit them. But small Churches with solo pastors, they have been using defined contribution plans or some form of "employer payment plan" since before Revenue Ruling 61-146 was i
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How to Complete the QSEHRA Employee Notice

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Our software does the initial notice for you. Employers offering a QSEHRA are required to provide all eligible employees with a notice that includes the following: The employee’s permitted amount for the year; An instruction to provide that information in any application for an Affordable Care Act (ACA) exchange premium subsidy; and A warning that the employee may be taxed under the ACA’s individual mandate, and owe income tax on QSEHRA reimbursements, unless he or she obtains “minimum essential coverage.” The IRS waived the notice requirement for 2017. For 2018, the notice requirement in in place. Our clients are pleased to know HRA Plan Docs creates the notice and delivers it with your plan documents, ready to distribute. We also provide clients with a "fillable" employee notice for new hires. The employee’s permitted amount for the year. The initial notice is distributable to all employees that will be eligible on the first day of the plan. For ne
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QSEHRA Contribution Limits Increase for 2018

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QSEHRA contribution limits for 2018 It is always amusing when the Service has a statutory deadline, like the October 1 deadline to provide QSEHRA participants written notice of their benefit, and releases helpful information weeks after said deadline. The IRS released the 2018 QSEHRA guidelines through Revenue Procedure 2017-58 on October 19, 2017. Luckily, HRA Plan Docs computed the increase from CPI in August so our clients were able to provide accurate employee notices. The 2018, QSEHRA contribution limits increased $200 annually for self-only employees and  $250 annually for employees with a family. An increase of roughly $16.66 per month for self-only employees and $20.83 for employees with a family. See the chart below for details: The maximum monthly allowance for 2017 Plans Employee Only $412.50 Employee w/ Dependent(s) $833.33 The maximum monthly allowance for 2018 Plans Employee Only $420.83 Employee w/ Dependent(s) $854.17
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