Qualified Small Employer Health Reimbursement Arrangement Susan 1

21st Century Cures Act Passed December 13, 2016 Allows a small employer to offer this special HRA to reimburse qualifying Section 213(d) medical expenses including coverage purchased on the individual market Susan 2 2

Confused – Implementation overload!! This is an exception to the ACA rule saying that there can be no HRA payments for individual medical premiums, and no HRA at all for employers not offering a group medical plan. Susan 3 3

Additional Guidance Coming To qualify, the employer cannot offer any group plan to it’s employees – medical, dental or vision Colette 4

The QSEHRA must be offered to all eligible employees May exclude Part-time employees Seasonal employees Employees with less than 90 days of service Employees under age 25 Colette 5 5

Employees must show proof of health insurance coverage in order to receive benefits under this Plan We are still awaiting guidance to find out exactly what the government means by “proof of coverage”. Leslie 6 6

What are some other rules? Only employers may contribute to this plan No employee contributions are permitted. Susan 7

What are some other rules? This benefit must be offered on the same terms to all employees The limits are: Employee only coverage - $4950 Employee plus family coverage - $10,000 Must be pro-rated monthly Susan 8

What else do we need to know? QSEHRA reimbursement amounts could impact potential marketplace subsidies Susan 9

Next Steps Notice must be provided 90 days before the plan year. However, no official guidance has been issued about this notice at all. There has been a suspension of this until the guidance comes out. Beth 10

We will keep you posted as more guidance is issued! 11