Applying Obamacare to Employer-Funded Health Benefit Plans

If your company offers its employees Health Reimbursement Arrangements (HRA), reimbursed group health plans, or health Flexible Spending Arrangements (FSA), you’ll need to pay careful attention to how these benefits will be treated under the Affordable Health Care Act.

Recently the U.S. Department of Labor issued Technical Release 2013-03 to provide guidance on the application of certain provisions of the Affordable Care Act to HRAs, reimbursed group health plans, and health FSAs. Read on for a summary of how these provisions could impact you and your company.

First off, beginning on January 1, 2014, many of these plans will no longer be able to impose an annual limit on the dollar amount of essential health benefits. In addition, non-grandfathered group health plans will be required to provide certain preventative services without imposing any cost sharing on the individual employee receiving the services.

This “no limit” coverage requirement has certain exceptions for “non-essential” services, including, among other things, accident-only coverage, disability income, certain limited-scope dental and vision benefits, certain long-term care benefits, and certain health FSAs.

Things get even more complicated when employer-funded health benefits are used to pay or help pay for group health plans.

This is an extremely complex set of requirements that demands close attention, particularly for those companies that may offer multiple employer-paid coverage options, or that combine employer-paid benefits with group health plans.

With a January 1 deadline looming, it is important to have your benefit plan evaluated to make sure it is in compliance with the Affordable Care Act.

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