PPACA Update:
IRS Releases Final Guidance for 1095-A and 1095-B on Employer HRA Groups


We are happy to share with you that the 1095-A and 1095-B filing requirements for Health Reimbursement Accounts (HRA's) have been fixed.  In early August, the IRS released draft instructions for 1095-A and 1095-B that included HRA filing requirements.  We reached out to the IRS through our nationwide affiliate, the National Association of Health Underwriters (NAHU), to communicate the negative impact these instructions would have on employer groups who offer an HRA in conjunction with their group health plan.  Last week, the IRS issued final instructions and the language has been modified to include our suggestions!

Please CLICK HERE to view the final IRS instructions 

The final instructions now state that an employer with a fully insured major medical plan and HRA coverage, for which the individual is eligible because they are enrolled in the employer group major medical plan, does not have the report the HRA value on the 1095-B form.  Specifically, the revised instructions now state:

An employer with an insured major medical plan and HRA coverage for which an individual is eligible because the individual enrolls in the insured major medical plan is not required to report the coverage on the HRA for individual coverage under the HRA for an individual covered by both arrangements.

There are some exceptions, most noteworthy is if an individual is covered by an HRA sponsored by one employer and a non-HRA group sponsored by another employer (such as coverage through a spouse).  in this situation each employer must report the coverage the employer provides.

We are very pleased with the action taken by the IRS on this issue as it illustrates the strength of our collective voices in Washington DC with respect to PPACA.  We will continue to advocate with Congress for the streamlining of employer reporting under the PPACA.  Please let us know if you have any questions or concerns.

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