Can ICHRAs Be Used to Make Healthcare a Defined Contribution Benefit?
The Affordable Care Act (ACA) limited employers’ ability to use Health Reimbursement Arrangements (HRAs) to fund individual premiums, except for Qualified Small Employer HRAs which had limited applicability due to legislative restrictions. Legislators were fearful that employers would use these programs to dump bad risk on the individual marketplace, which under ACA now has a pre-existing condition ban. Makes sense – large claims make up a disproportionate share of an organization’s total claims, and an employer would get a windfall if it could remove those individuals from its plan. In 2017, the Trump administration directed the U.S. Treasury …
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