The IRS meant it when it said that all employers, regardless of size, will be liable for a $100 per day, per employee, excise tax if they pay for or reimburse employees who buy individual health insurance either on or off the individual exchange. Sort of. It’s now providing transition relief to certain employers and to certain reimbursement arrangements. (Notice 2015-17, IRB 2015-14)
Recap: employer payment plans. Employers without group health plans have been using employer payment plans (EPPs), under which they pick up some or all of employees’ substantiated individual health premiums, since 1961. Today, EPPs commonly take the form of health reimbursement arrangements (HRAs).
In Notice 2013-54, the IRS concluded that stand-alone HRAs don’t meet the Affordable Care Act’s (ACA) market reforms, including not imposing annual limits for essential health benefits and providing free preventive care. HRAs must be integrated into ...(register to read more)