You may not yet have heard about a new type of health plan arrangement created in December 2016 for small employers – the “QSEHRA”. Many employers, particularly small employers, were adversely affected by a change in the law prohibiting employers from reimbursing employees for the cost of their individual health policies. Under this new law, Qualified Small Employers can adopt a Health Reimbursement Arrangement that complies with the rules set out in Internal Revenue Code Section 9831(d). These new arrangements are available only to employers with less than 50 full-time employees and full-time equivalent employees who offer no health plan coverage to its employees. A QSEHRA can reimburse employees who provide proof of other medical coverage for various medical expenses, including, importantly, the cost of individual health insurance, up to $4,950 for employee only coverage and $10,000 for family coverage (additional requirements apply).Code Section 9831(d) provides a very specific notice requirement regarding its timing and content. Because not much guidance relating to this notice requirement has been issued, the IRS just released transition relief in Notice 2017-20 waiving the notice requirement until additional guidance is issued. More information about this limited type of a stand-alone HRA can be found at https://www.dol.gov/sites/default/files/ebsa/about-ebsa/our-activities/resource-center/faqs/aca-part-35.pdf
While we are pleased to have you contact us by telephone, surface mail, electronic mail, or by facsimile transmission, contacting Kilpatrick Townsend & Stockton LLP or any of its attorneys does not create an attorney-client relationship. The formation of an attorney-client relationship requires consideration of multiple factors, including possible conflicts of interest. An attorney-client relationship is formed only when both you and the Firm have agreed to proceed with a defined engagement.
DO NOT CONVEY TO US ANY INFORMATION YOU REGARD AS CONFIDENTIAL UNTIL A FORMAL CLIENT-ATTORNEY RELATIONSHIP HAS BEEN ESTABLISHED.
If you do convey information, you recognize that we may review and disclose the information, and you agree that even if you regard the information as highly confidential and even if it is transmitted in a good faith effort to retain us, such a review does not preclude us from representing another client directly adverse to you, even in a matter where that information could be used against you.