The Internal Revenue Service has threatened employers with Affordable Care Act penalties of $36,500 per employee, per year, nondeductible. Makes those $2,000 and $3,000 penalties look like small potatoes, right?
The targets of this particular Q&A are employers who maintain non-integrated employer payment plans. These are new terms, which include reimbursement plans such as health reimbursement arrangements (HRAs, excluding retiree-only and excepted benefits HRAs). Those should generally have been eliminated by Jan. 1, 2014, or amended to be integrated with group health coverage.
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