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Update - IRS releases FAQ Clarifying Integrated HRA Administration


This is an update to our December 2016 blog post (IRS Updates Will Impact School, City and County HRA Plans in 2017) regarding IRS Notice 2015-84 – Dependents seeking reimbursements from an HRA.

The Department of Labor, Health and Human Services and the Treasury released FAQ #37 on the implementation of the Affordable Care Act. The FAQ clarifies that an Health Reimbursement Arrangement (HRA) covering employees, spouse and eligible dependents may be considered integrated with a combination of group health coverage (i.e. the employee’s and spouse’s group health plans). Also the group coverage does not need to be under the same plan sponsor as long as it meets the integration requirements. Additionally, spouses and/or dependents are able to seek reimbursement from the participant’s HRA if the participant has self-only group coverage and the spouse and/or dependent have group coverage through a separate source. The employer may rely on “reasonable representation” of any employee that his or her spouse and/or dependents have group coverage.

For those clients with an Integrated HRA with National Insurance Services and MidAmerica Administrative & Retirement Solutions, the claim form has been updated to include an attestation that spouses and/or dependents have group coverage and are eligible for reimbursements.

For questions, contact Beth Lauck, Retirement Income Service Manager.

National Insurance Services is not a law firm and no opinion, suggestion, or recommendation of the firm or its employees shall constitute legal advice. Readers are advised to consult with their own attorney for a determination of their legal rights, responsibilities and liabilities, including the interpretation of any statute or regulation, or its application to the readers’ business activities.

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Beth Lauck

Beth Lauck

Working at National Insurance Services is a natural fit for Beth Lauck since its core values and dedication to “making local schools and communities better” closely matches her personal values. Her past employment includes over five years as a trial attorney working in the juvenile courts. Having worked in the public sector, she knows first-hand the kind of challenges schools and government agencies face. As Retirement Income Service Manager, Beth oversees the department’s service operations and manages the Retirement Income Account Representatives and Service Coordinator. She also provides technical, administrative and compliance support to customers. Beth is a licensed attorney, licensed Life and Health Insurance agent and a registered representative with Series 6 and 63 licenses. Outside of work, Beth is actively involved in the community. She serves on the board of a local nonprofit assisting homeless families and children, teaches religious education to middle-school youth at her church and serves as a volunteer advocate and pro-bono attorney for families involved in the Milwaukee County child welfare system.