Compliance Notice 2015-87

The Lead March 2016 - Lifetime Benefit Solutions

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Compliance Notice 2015-87

Compliance Notice 2015-87 Breakdown - Lifetime Benefits Solutions - The Lead March 2016

The ruling:
December 2015: IRS, DOL and HHS got together to issue IRS Notice 2015-87, which provides further guidance on the application of the group health plan market reform provisions of the Affordable Care Act to employer-provided health coverage. The notice covers health reimbursement arrangements (HRA), including HRAs integrated with a group health plan, and group health plans under which an employer reimburses an employee for some or all of the premium expenses incurred for an individual health insurance policy. It also covers the treatment of flex credit contributions and Health Flexible Spending Account (FSA) carryover clarifications.
The ramifications:
Overall, these changes impact both eligibility and affordability when HRA, FSA or Flex Credits are part of your employee benefit plan. We encourage employers to understand these impacts and to ensure their guidelines – specifically relating to plan documents and employee participation – follow guidance.

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