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Final Rule on Health Reimbursement Arrangements for Individual Coverage: Employer Options for Providing Health Benefits - On-Demand

Final Rule on Health Reimbursement Arrangements for Individual Coverage: Employer Options for Providing Health Benefits - On-Demand

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Final Rule on Health Reimbursement Arrangements for Individual Coverage: Employer Options for Providing Health Benefits - On-Demand

Webinar now available On-Demand.

WEBINAR SNAPSHOT: Learn how the newly released final rule on health reimbursement arrangements (HRAs) will impact your options for health plan design and possible alternatives to traditional group health coverage.


The Departments of Health and Human Services, Labor, and Treasury have issued a final rule expanding the use of health reimbursement arrangements (HRAs) to fund active employees’ individual market major medical health insurance premiums.

This final rule covering individual coverage health reimbursement arrangements (ICHRAs) is a reversal in course from previous federal guidance and largely follows what was outlined in the proposed rule last year.  

Beginning January 1, 2020, the final rule gives employers an “individual coverage HRA” option for subsidizing employees’ purchase of individual health insurance and the option of providing an “excepted benefit HRA” to help employees with copayments, deductibles, and dental/vision coverage.

An excepted benefit HRA allows an employer to offer employees a non-integrated HRA (i.e., it doesn’t require the participant to be enrolled in any other coverage that reimburses general medical expenses—up to a limited amount). 

Employers understandably have many pressing questions ahead of the final rule taking effect. Don’t delay in getting the answers you need to navigate the changing HRA landscape.

Use this on-demand webinar when employee benefits attorney Ashley Gillihan of Alston & Bird LLP will summarize the final rule and its practical impact on employees’ healthcare coverage and traditional employer-sponsored health plans.

You’ll learn:

  • The practical impact the final rule on HRAs, which takes effect January 1, 2020, will have on employees
  • What an ICHRA is, and who can be offered one  
  • The maximum reimbursement for an ICHRA
  • Whether an ICHRA constitutes minimum essential coverage
  • Whether applicable large employers can use an ICHRA to satisfy the employer shared responsibility rules
  • What an excepted benefit HRA is, and the maximum amount of an excepted benefit HRA
  • Who can be offered an excepted benefit HRA
  • Where the final rule on HRAs fits in with other final rules on association health plans and short-term coverage 

About Your Presenter

Ashley GillihanAshley Gillihan, Esq.
Alston & Bird LLP

Ashley Gillihan is counsel in the Atlanta office and a member of Alston & Bird LLP’s Employee Benefits & Executive Compensation and ERISA Litigation Groups. He focuses his practice exclusively on health and welfare employee benefit compliance and litigation issues for employers, health plan administrators and other health and welfare benefit plan service providers. He also has extensive experience assisting financial institutions and insurance companies who serve as Health Savings Account trustees or custodians.

Gillihan is active in publishing and speaking on various health and welfare benefit plan related topics and serves as a faculty member and/or technical advisor for several health and welfare benefit plan focused organizations.

He is a member of the Employer’s Council on Flexible Compensation (ECFC) Technical Advisory Council and the board of editors for the Benefits and Compensation Law Alert, published by M. Lee Smith Publishers. He was named to the Benefits Committee for the Self-Insurance Institute of America, Inc. and served from 2007–2008. He is also a faculty member for the Institute for Applied Management and Law (IAML) and is the former author of the Flexible Benefits Answer Book published by Aspen Publishers.