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 IRS guidance, issued as a 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.
