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September 17, 2015

IRS Provides Reporting Relief to HRAs Integrated with Health Plans

The IRS today released Final Instructions to ACA Reporting forms 1094-B and 1095-B which remove the "MEC Reporting" obligation for many employer HRAs.

Although the "Draft" instructions released last month included a reporting requirement, the Final Instructions provide relief to HRAs that are integrated with either fully insured or self-funded coverage sponsored by the SAME employer.

Arrangements that are integrated with OTHER employer coverage or which are not integrated with ANY employer coverage apparently will still be required to report.

For more information, see page 3 of the Final Instructions linked here: Instructions for 1094-B and 1095-B.