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IRS Provides Additional Guidance on Health Care Reform Issues for Employer-Sponsored Health Plans

Visit the Health Care Reform Community on Checkpoint to join the discussion on this development (for Checkpoint subscribers to EBIA’s Health Care Reform manual).

The IRS has issued additional guidance on how various health care reform provisions apply to HRAs, health FSAs, HSAs, and other employer-sponsored health plans. IRS Notice 2015-87 includes 26 questions and answers addressing topics such as HRA integration; employer payment plans and the purchase of individual market coverage; affordability determinations (including treatment of HRA contributions, flex credits, and opt-out payments) and related reporting issues; issues arising under Code § 4980H; interaction of the HSA eligibility rules with veterans’ benefits; and health FSA carryovers (including COBRA issues). Portions of the guidance within the shared jurisdiction of HHS and the DOL have also been reviewed and approved by those agencies.

We will cover this development in the December 22, 2015 EBIA Weekly. Meanwhile, for more information about the topics addressed in the guidance, see EBIA’s Health Care Reform, Cafeteria Plans, COBRA, and Consumer-Driven Health Care manuals, and EBIA’s Form 1094/1095 Workbook.

Contributing Editors: EBIA Staff.

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