February 25, 2015 by Tony Novak
I received an interesting question about a small business Health Reimbursement Arrangement (HRA) operated by a small C corporation in Washington state. The only employees are husband and wife. The husband is on Medicare and the wife has a grandfathered individual health insurance plan. Most of the HRA plans I hear about fail to meet one or another of ACA requirements but in this case it seems like the plan will work with minor updates. I need to review IRS Notice 2015-17 Question #3 with regard to Medicare integration of small business HRAs before giving a final answer but I am likely to offer a single consultation to help the couple update the HRA plan.