Anytime a ruling is issued by “the departments”, (Treasury, IRS and DOL) it is
met with excitement and anticipation. But on the rare occasion we're left
scratching our heads. That's the case with the Friday the 13th
ruling, handed down in September.
This
ruling took previous guidance on health reimbursement arrangements (HRAs) and expanded it to
“employer payment plans”. The case was made, that to follow the affordable
care act “employer payment plans” must conform with the no annual limit benefit
provision, thus no longer pre-taxing individual policies through an employer. I
can't quite wrap my head around the notion of why “the departments” would want
to make a ruling that counters so much previous guidance by those same
departments?
By
taking away the pre-taxing of individual policies through an employer payment
plan, the government essentially made purchasing individual policies through
the exchanges equal. Instead of figuring out a fair and adequate way
to make policies eligible for pre-taxing through the exchanges, they
eliminated it for hundreds of thousands of individual policyholders that
enjoyed lower premiums, portable coverage and employer help in paying for those
policies.
If
we're all ready to have a conversation to sort this out, I have an opening Thursday.
The Author: Roger Jorgensen, RHU, REBC
Marketing - HSA/HRA/FSA & COBRA
rjorgensen@abg-mn.com
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