New Opportunities Provided by the Final HRA Regulations

New Opportunities Provided by the Final HRA Regulations
July 24, 2019 Kim Wilcoxon, Partner

Today’s Presentation Overview of the two new types of HRAs that will be available beginning in 2020 Comparison of the new HRAs to currently- available and commonly used HRAs Discussion of how the HRAs may satisfy the ACA employer mandate Additional considerations Requirements for establishing and maintaining the HRAs

Overview of New HRAs

New HRAs Individual Coverage HRA
Allows employees to use non-taxable employer contributions to purchase individual insurance May also reimburse any other Code Section 213(d) medical expenses Employer may not offer a traditional group health plan to employees eligible for this type of HRA The HRA must be offered, and generally must be offered on the same terms, to all members of a permitted class

Permitted Classes Full-time employees* Part-time employees*
Seasonal employees* Salaried employees Non-salaried employees Employees covered by a particular collective bargaining agreement Employees who have not satisfied a waiting period Non-resident aliens with no U.S.-based income Employees whose primary site of employment is in the same rating area Staffing agency employees who are temporarily placed with a customer *As defined by Code Section 105(h) or 4980H – employer must choose before the beginning of the plan year and include definition in plan document

New HRAs Excepted Benefit HRA
Allows employees to use non-taxable employer contributions to reimburse Code Section 213(d) medical expenses other than premiums for Individual health insurance (with certain exceptions) Group health plans (with certain exceptions) COBRA premiums may be reimbursed Medicare Parts A, B, C or D Employer must offer a traditional group health plan to employees eligible for this type of HRA, but need not integrate the HRA with any health plan Different from an HRA that reimburses only excepted benefits

Comparison to Common Existing HRAs

Individual Coverage HRA
GHP Integrated HRA Retiree-Only HRA QSEHRA Individual Coverage HRA Any employer may offer Offered only by non-ALEs Employer must offer a traditional group health plan No requirement to offer other coverage Employer may not offer other health coverage Employer may not offer a traditional group health plan to employees in the eligible class No requirements regarding eligibility (nondiscrimination rules apply) May not cover more than 1 current employee Must be offered to all employees (with limited exclusions) and no former employees Must offer to all members of the eligible class Dollar limit set by plan sponsor $5,050/$10,250 (adjusted) May not reimburse individual insurance premiums May reimburse individual insurance premiums

GHP Integrated HRA Retiree-Only HRA QSEHRA Excepted Benefit HRA
Any employer may offer Offered only by non-ALEs Employer must offer a traditional group health plan No requirement to offer other coverage Employer may not offer other health coverage No requirements regarding eligibility (nondiscrimination rules apply) May not cover more than 1 current employee Must be offered to all employees (with limited exclusions) and no former employees Must offer to all similarly situated individuals Dollar limit set by plan sponsor $5,050/$10,250 (adjusted) $1,800 (adjusted) May not reimburse individual insurance premiums May reimburse individual insurance premiums May not reimburse individual insurance premiums other than STLDI or excepted benefits

Individual Coverage HRA Excepted Benefit HRA
GHP Integrated HRA Retiree-Only HRA QSEHRA Individual Coverage HRA Excepted Benefit HRA HRA Reimbursing Only Excepted Benefits Group Health Plan Yes No Subject to COBRA Subject to HIPAA privacy/ security* Requires plan document/SPD Requires SBC Yes** Is minimum essential coverage *Unless the plan meets exceptions specified in the HIPAA privacy/security rules ** May be reported on the medical plan SBC

Possible Combinations
May offer GHP Integrated HRA Retiree HRA Excepted Benefits HRA HRA reimbursing only excepted benefits May not offer QSEHRA Individual Coverage HRA (to same class of employees)

May offer Individual Coverage HRA Retiree HRA HRA reimbursing only excepted benefits May not offer QSEHRA GHP Integrated HRA (to same class of employees) Excepted Benefits HRA (to same class of employees)

May offer QSEHRA Retiree HRA May not offer GHP Integrated HRA Individual Coverage HRA Excepted Benefits HRA HRA reimbursing only excepted benefits

Application of ACA Employer Mandate

Employer Mandate Refresher
4980H(a) penalty: Employer offers coverage to less than 95% of its ACA full- time employees At least one ACA full-time employee purchases a Marketplace policy and qualifies for a premium tax credit 4980H(b) penalty: Employer offers coverage to at least 95% of its ACA full- time employees Employer does not offer affordable, minimum value coverage to at least one ACA full-time employee That employee purchases a Marketplace policy and qualifies for a premium tax credit

Impact on Employer Mandate
An employer that offers an Individual Coverage HRA: Will have made an offer of coverage under 4980H(a) Will need to offer an affordable HRA in order to avoid a penalty under 4980H(b) Notice proposed a safe harbor and requested comments Treasury/IRS plan to issue proposed regulations addressing comments from Notice Determination likely will be similar to the affordability determination for the premium tax credit, with certain modifications

Impact on Premium Tax Credit Eligibility
Individual who is covered by an Individual Coverage HRA is ineligible for the premium tax credit Individual who is eligible for, but opts out of, an Individual Coverage HRA is ineligible for the premium tax credit for any month in which the HRA is affordable and provides minimum value coverage HRA coverage is affordable if the employee’s “required HRA contribution” does not exceed: (1/12) x (employee’s household income) x (required contribution percentage) Note: Additional details regarding premium tax credit eligibility apply but are outside the scope of this presentation

Impact on Premium Tax Credit Eligibility
The required HRA contribution is equal to: The monthly premium for the lowest cost silver plan for self- only coverage available to the employee through the Marketplace for the rating area in which the employee resides minus The amount newly made available to the employee for self- only coverage for the plan year ÷ the number of months in the plan year that the HRA is available to the employee The required contribution percentage is 9.56%, adjusted for inflation (9.86% for 2019)

Impact on Premium Tax Credit Eligibility - Example
Employer’s self-only contribution for a plan year is $3,000 Employee’s household income is $20,000 Employee is enrolled in a calendar year Individual Coverage HRA for the full calendar year Monthly premium for lowest cost silver plan is $400 Required contribution percentage is 9.86% The employee’s required HRA contribution May Not Exceed (1/12) x (employee’s household income) x (required contribution percentage) The monthly premium for the lowest cost silver plan for self-only coverage available to the employee through the Marketplace for the rating area in which the employee resides minus The amount newly made available to the employee for self-only coverage for the plan year ÷ the number of months in the plan year that the HRA is available to the employee (1/12) x ($20,000) x (9.86%) $400 – ($3,000 ÷12) (1/12) x $1,972 $150 $164.33

Affordability As Proposed Under Notice 2018-88 – Example 1
Employer’s self-only contribution for a plan year is $3,000 Employee’s household income is $20,000 Employee is enrolled in a calendar year Individual Coverage HRA for the full calendar year Monthly premium for lowest cost silver plan is $400 Required contribution percentage is 9.86% The employee’s required HRA contribution May Not Exceed (1/12) x (employee’s household income) x (required contribution percentage) The prior year’s monthly premium for the lowest cost silver plan for self-only coverage available to the employee through the Marketplace for the rating area in which the employee resides that contains the employee’s worksite location minus The amount newly made available to the employee for self-only coverage for the plan year ÷ the number of months in the plan year that the HRA is available to the employee (1/12) x ($20,000) x (9.86%) $400 – ($3,000 ÷12) (1/12) x $1,972 $150 $164.33

Affordability As Proposed Under Notice 2018-88 – Example 2
Employer’s self-only contribution for a plan year is $3,000$1,200 Employee’s household income is $20,000$45,000 Employee is enrolled in a calendar year Individual Coverage HRA for the full calendar year Monthly premium for lowest cost silver plan is $400 Required contribution percentage is 9.86% The employee’s required HRA contribution May Not Exceed (1/12) x (employee’s household income) x (required contribution percentage) The prior year’s monthly premium for the lowest cost silver plan for self-only coverage available to the employee through the Marketplace for the rating area in which the employee resides that contains the employee’s worksite location minus The amount newly made available to the employee for self-only coverage for the plan year ÷ the number of months in the plan year that the HRA is available to the employee (1/12) x ($20,000) x (9.86%) (1/12) x ($45,000) x (9.86%) $400 – ($3,000 ÷12) $400 – ($1,200 ÷12) (1/12) x $1,972 (1/12) x $4,437 $150 $300 $164.33 $369.75

Additional Considerations

Application of ERISA Individual insurance purchased through an HRA will not be subject to ERISA or treated as a group health insurance if: The purchase of individual insurance is completely voluntary The employer does not select or endorse any particular issuer or individual health insurance coverage Employer may provide general contact information for insurance available in a state and may provide general health insurance educational information Reimbursement is limited to individual health insurance coverage that does not consist solely of excepted benefits Employer does not receive consideration in connection with the employee’s selection or renewal of individual insurance coverage This requirement is not intended to affect the plan’s ability to reimburse the employer for certain administrative expenses Each plan participant receives an annual notice that the individual insurance coverage is not subject to ERISA

Application of ERISA Rule applies to Individual Coverage HRA QSEHRAs
Retiree-only HRAs Other HRAs that are offered to fewer than two current employees on the first day of the plan year Cafeteria plans that allow employees to pay for the portion of individual insurance premiums not covered by the integrated HRA or QSEHRA

Impact on HSAs Limited-purpose and/or post-deductible individual coverage HRAs will not disqualify individuals from eligibility for HSA contributions It is the employer’s responsibility to ensure that a post- deductible HRA does not reimburse expenses before the employee satisfies the deductible A limited purpose HRA that permits reimbursement of premiums is not disqualifying coverage unless the individual uses the HRA to purchase disqualifying coverage

Individual Market Special Enrollment
An individual will have a special enrollment right to enroll in individual health insurance coverage (through or outside the Marketplace) when the individual newly gains access to an Individual Coverage HRA Applies when employer first begins to offer the plan Applies when employee first becomes eligible Individuals may request enrollment up to 60 days in advance of the effective date of the HRA coverage Individual health insurance coverage must become effective as of the later of The first day of the first month following the individual’s plan selection The first day of the first month coincident with or next following the effective date of the HRA coverage

Requirements for Individual Coverage HRAs

Individual Insurance Market Stabilization
Scenario 1 1,000 individuals each pay $100 in premiums to Insurance Company (total $100,000) 1 paying individual incurs $25,000 in claims Net gain of $75,000

Scenario 2 1,000 individuals each pay $100 in premiums to Insurance Company (total $100,000) 1,000 paying individuals each incur $25,000 in claims (total $25,000,000) Net loss of $24,900,000

Higher percentage of insured persons incur claims Insurance company increases premiums Healthier insureds drop out

ACA Market Reform Rules
Group health plans may not impose annual or lifetime dollar limits on essential health benefits Non-grandfathered plans must cover all recommended preventive care services

Overview of Requirements
Participants and any dependents covered by the HRA must be enrolled in individual health insurance that complies with the ACA rules on lifetime/annual dollar limits and coverage of preventive services HRA must be offered on the same terms to all members of the same class Class-based rules apply on an employer-by-employer basis, not on a controlled group basis Minimum class size requirement may apply Initial and annual notices must be provided Model notice is available Participants must be given the opportunity to opt out of coverage annually (but not during the plan year) and upon termination The regulations also describe a safe harbor under which individual insurance policies do not become the employer’s ERISA plans

Requirement to Maintain Individual Insurance Coverage
HRA must require participants and any dependents covered by the HRA to be enrolled in individual health insurance that complies with the ACA rules on lifetime/annual dollar limits and coverage of preventive services This requirement will not be met if the participant is enrolled in Excepted benefits Short-term limited duration insurance TRICARE All other coverage in the individual insurance market is presumed to be compliant with the ACA rules No exclusion for coverage in states with a Section 1332 state innovation waiver No exclusion for catastrophic policies No exclusion for grandfathered or grandmothered policies No exclusion for student health insurance

Due to the interaction of various federal rules relating to Medicare and individual insurance, a Medicare-eligible individual may be enrolled in Medicare instead of an individual insurance policy If not enrolled in individual coverage, the covered person must be enrolled in Medicare Part A and B or Medicare Part C The participant and all dependents do not need to be enrolled in the same type of coverage Ex: Employee is enrolled in Medicare Parts A and B while the dependents are enrolled in an individual insurance policy All other individual coverage HRA rules apply in the same manner Future guidance is expected to address how the Medicare Secondary Payer mandatory reporting rules apply to Individual Coverage HRAs

If any covered individual ceases to be enrolled in individual insurance coverage, expenses incurred by that individual after such coverage ceases may not be reimbursed If all covered individuals cease to be enrolled in individual insurance coverage, the participant must forfeit the HRA Note: Loss of coverage under an HRA due to cessation of enrollment in individual insurance coverage is not a COBRA qualifying event

There is no requirement that an HRA cover all of a participant’s dependents However, the HRA must comply with the ACA’s rules on coverage for children until age 26 The HRA could be designed to allow the participant to exclude certain dependents

The HRA must implement reasonable procedures to substantiate the required coverage The procedures must require substantiation annually before the beginning of each plan year and with every reimbursement request The procedures may require the participant to provide either of the following (Annual substantiation requirement only) A document from a third party confirming enrollment of the participant and applicable dependents, such as Explanation of benefits or Insurance card or A document from an Exchange confirming that the individual completed an application and plan selection Attestation by the participant, including the date coverage began and name of provider

The employer may establish the deadline for providing the annual substantiation The substantiation generally must be provided before the beginning of the plan year For employees hired during the plan year or within 90 days before the beginning of the plan year, the employer may establish a separate deadline for providing substantiation Deadline must be prior to the effective date of coverage The annual substantiation must indicate that the individual coverage applies for the full plan year If the individual policy year does not match the HRA plan year, the procedures may require attestation that the participant will obtain coverage for the remainder of the HRA plan year

The HRA may rely on the documentation or attestation unless the HRA has actual knowledge that the participant or covered dependent is not - or will not be – enrolled in individual health coverage for the applicable time period If the HRA gains actual knowledge, the HRA may not permit further reimbursement of expenses incurred during the time period covered by the inaccurate documentation/attestation The HRA has actual knowledge if any of the following entities has actual knowledge The HRA The plan sponsor Any entity acting in an official capacity on behalf of the HRA

Class-Based Rules Employer may not offer the same class of employees a choice between the employer’s traditional group health plan and the HRA “Traditional group health plan” does not include A plan that offers only excepted benefits Another account-based plan The HRA must be offered on the same terms to all employees within the same class Class-based rules apply separately to each employer and do not apply on a controlled group basis

Requirement to Offer to Full Class
The HRA may be offered only to a subset of former employees within a class If the HRA is offered to a former employee, it must be offered on the same terms applicable to employees in the same class An HRA may not vary the maximum reimbursement amount by age or years of service A former employee is considered to be in the same class that he or she was in immediately prior to separation from service Remember: Retiree-only HRAs are exempt from these rules

Requirement to Offer Same Terms to Class
The rules do not establish minimum or maximum reimbursement amounts. Those amounts may be determined by the plan sponsor but must satisfy the “same terms” requirements An HRA will not be considered to have been offered on the same terms if the plan is designed to reimburse the same percentage of each employee’s individual health insurance premiums

The maximum reimbursement amount for a class may increase based on age The same maximum reimbursement amount must apply to all employees of the same age in the same class The maximum reimbursement amount available to the oldest participant cannot be more than three times the maximum reimbursement amount available to the youngest participant Age may be determined under any reasonable method, so long as The same method is used for all participants in the same class and The method is determined before the beginning of the plan year

The maximum reimbursement amount for a class may increase based on number of dependents covered The same maximum reimbursement amount must apply to all employees with the same number of dependents in the same class

If an employee is hired during the plan year, the HRA may provide the full maximum reimbursement amount or may use a reasonable proration method If the HRA varies the maximum reimbursement amount by number of dependents and the employee adds or loses a dependent during the plan year, the HRA may determine the maximum reimbursement amount Based on the number of dependents as of the first plan year or Using a reasonable proration method for the rest of the year For both situations, the HRA’s approach must be the same for all members of the same class and must be determined before the beginning of the plan year

The method for determining whether previously-credited amounts remain available must be the same for all participants in the same class The “maximum reimbursement amount” will not include any amounts carried over from a prior year The “maximum reimbursement amount” will not include any amounts transferred from another HRA

HRA Transfers Unused amounts in an Individual Coverage HRA may be transferred to Another Individual Coverage HRA Group Health Plan integrated HRA Medicare/Tricare integrated HRA Unused amounts in an integrated group health plan HRA may be transferred to Another Group Health Plan integrated HRA Individual Coverage HRA Unused amounts in a Medicare/Tricare integrated HRA may be transferred to Another Medicare/Tricare integrated HRA Unused amounts in an HRA may not be cashed out or transferred to an FSA or HSA

The Plan Sponsor may offer employees in a class a choice between an HSA-compatible Individual Coverage HRA and a non-HSA-compatible Individual Coverage HRA Both HRAs must be offered to all employees in the class on the same terms The timing of credits to the HRA (annually, monthly, quarterly, etc.) must be the same for all employees in the same class

The ability to use salary reductions under a cafeteria plan to pay for the portion of premiums not covered by the HRA is a term of the HRA that must be applied in the same way to all employees within a class Cafeteria plans may not provide for the purchase of Marketplace policies Cafeteria plans may provide for the purchase of individual policies outside the Marketplace

Permitted Classes Full-time employees* Part-time employees*
Seasonal employees* Salaried employees Non-salaried employees Employees covered by a particular collective bargaining agreement Employees who have not satisfied a waiting period Non-resident aliens with no U.S.-based income Employees whose primary site of employment is in the same rating area Staffing agency employees who are temporarily placed with a customer *As defined by Code Section 105(h) or 4980H – employer must choose before the beginning of the plan year and include definition in plan document

Permitted Classes Permitted classes
Classes are determined on an employer-by-employer basis, not a controlled group basis Retirees are considered to be in the class they were in immediately before separation from service The HRA may be offered only to those employees in a class that are hired on or after a certain date The minimum class size requirement would not apply to the new-hire subclass The date must be on or after January 1, 2020 A traditional group health plan may be offered to members of the class hired before the applicable date The employer may change this rule at any time and treat all members of the class in the same manner

Minimum Class Size Requirement
Applies only where an employer offers a traditional group health plan to at least one class of employees and offers an Individual Coverage HRA to at least one other class of employees Applies only to the classes offered the Individual Coverage HRA Applies only to the following classes Salaried employees Non-salaried employees Full-time employees (but only if a traditional group health plan is offered to part-time employees) Part-time employees (but only if a traditional group health plan is offered to full-time employees) Employees whose primary site of employment is in the same rating area (unless the geographic area is an entire state or combination of entire states) Any combination involving one of the above classes (unless the combination involves the waiting period class)

Minimum Class Size Requirement
Differs based on employer size The number of employees is based on the employer’s reasonable expectation of the number of employees that will be employed on the first day of the plan year Compliance with the requirement is based on the number of employees offered the Individual Coverage HRA as of the first day of the plan year Number of Employees Minimum Class Size Less than 100 10 100 to 200 10% of the number of employees (rounded down to a whole number) More than 200 20

Examples: Traditional health plan offered to full-time employees and HRA offered to part-time employees (Minimum class size requirement must be met) No traditional health plan offered, and HRA excludes non- resident aliens with no U.S.-based income No traditional health plan offered, and HRA offers: $5,000 maximum reimbursement to non-union full-time employees $3,000 maximum reimbursement to non-union part-time employees $3,500 maximum reimbursement to union full-time employees covered by CBA #1 $2,500 maximum reimbursement to union part-time employees covered by CBA #1 $4,000 maximum reimbursement to union employees covered by CBA #2

Examples: No traditional health plan offered, HRA available only to full- time employees, and HRA offers: $5,000 maximum reimbursement to employees with no dependents $7,500 maximum reimbursement to employees with one or more dependents No traditional health plan offered and HRA offers: $5,000 maximum reimbursement to full-time employees under age 50 $6,000 maximum reimbursement to full-time employees who are at least age 50 $3,000 maximum reimbursement to part-time employees under age 50 $4,000 maximum reimbursement to part-time employees who are at least age 50

Impact of Transfers Between Classes
Example: Employer offers an Individual Coverage HRA to part-time employees and a traditional group health plan to full-time employees Full-time to part-time: Employee loses coverage under the traditional group health plan due to a reduction in hours and becomes eligible for the Individual Coverage HRA. Must offer COBRA under the traditional group health plan Part-time to Full-time: Employee loses coverage under the Individual Coverage HRA and becomes eligible for the traditional health plan Need not offer COBRA under the Individual Coverage HRA because the loss of coverage is not due to a qualifying event The HRA may specify a run-out period during which the employee must request reimbursement for expenses incurred prior to the date of the transfer

Notice Requirement Participants must receive a notice explaining how the HRA impacts eligibility for the premium tax credit By the date the HRA will first become effective for the participant At least 90 days before the beginning of each plan year A model notice and model language is available but not required Participants must also receive A summary of benefits and coverage A summary plan description

Notice Requirement Content of notice
Description of the terms of the HRA, including: The maximum reimbursement amount for each participant Any rules regarding the proration of the maximum reimbursement amount for participants who are not eligible for the entire plan year Whether (and which of) a participant's family members are eligible for the HRA The fact that the plan is an individual coverage HRA and not a QSEHRA or other type of HRA A statement that the plan requires the participant and all dependents to be enrolled in individual insurance coverage A statement that the individual insurance coverage may not be STLDI or excepted benefits If applicable, a statement that the individual insurance coverage is not subject to ERISA The date as of which the HRA coverage may first become effective and the date of the beginning or end of the plan year

Notice Requirement Content of notice
A statement of the right to opt-out and wave future reimbursements Description of the potential availability of the premium tax credit and the impact of the offer of the HRA on eligibility for the premium tax credit A description of the premium tax credit eligibility consequences for a participant who is covered under the HRA A statement describing how to find assistance with determining affordability A statement that, if the participant applies for the premium tax credit through a Marketplace, the participant must inform the Marketplace of the availability of the HRA and certain details about the HRA A statement that the participant should retain the written notice because it may be needed to determine whether the participant is allowed the premium tax credit A statement of availability of a Marketplace special enrollment period for persons newly becoming eligible for the HRA A statement that the participant is required to substantiate enrollment in individual insurance coverage A statement that the HRA may not reimburse any medical care expense unless the substantiation requirements are met A statement that the HRA will not reimburse expenses incurred after coverage ceases A statement that it is the responsibility of the participant to inform the HRA if the participant or any applicable dependent is no longer enrolled in individual health insurance coverage and the effective date of cancellation or termination of coverage Contact information (at least a phone number) for the person(s) who can answer questions about the HRA

Notice Requirement Method of delivery ERISA rules apply
Must be reasonably calculated to ensure actual receipt Electronic distribution safe harbor is not the only method by which electronic distribution can be compliant May be combined with other materials

Opt-Out Opportunities
Participants must be allowed to opt out of the HRA and waive future reimbursements annually, in advance of the plan year The employer may establish the time periods for enrolling in or opting out of the HRA The HRA may not allow eligible persons to enroll in or opt out during the plan year except following termination of employment Upon termination of employment, either Any remaining amounts are forfeited or The participant can elect to permanently opt out and waive future reimbursements If an employee/former employee opts out of HRA coverage, any eligible dependents are also considered to have opted out

Requirements for Excepted Benefit HRAs

Treatment as an Excepted Benefit
Applies to all account-based plans other than health flexible spending accounts (“HRAs”) HRA must not be an integral part of the plan Other group health plan coverage (other than excepted benefits or another HRA) must be made available by the same plan sponsor to participants offered the HRA The participant need not enroll in the other group health coverage HRA must provide benefits that are limited in amount Amounts made newly available for reimbursement for a plan year may not exceed $1,800 (to be adjusted for years beginning after using C-CPI-U) Amounts made available to a participant by an employer under multiple HRAs (other than HRAs that reimburse only excepted benefits) will be aggregated to determine whether the limit has been exceeded Funds carried over are disregarded Adjustments will be announced by June 1 of the prior year

Permitted Reimbursements
HRA cannot provide reimbursement for premiums for certain health insurance coverage Cannot provide reimbursement for Individual health insurance (except as noted below) Group health plans (except as noted below) Medicare Parts A, B, C, or D May provide reimbursement for Individual health insurance or group health plan coverage that consists solely of excepted benefits Short term limited duration insurance (unless provided otherwise by HHS) COBRA or other group continuation coverage Other coverage not explicitly excluded

Treatment as an Excepted Benefit
HRA must be made available under the same terms to all similarly situated individuals, regardless of any health factor “Similarly situated individuals” has the same meaning given under the HIPAA nondiscrimination rules Benign discrimination not permitted Example: Employer may not make greater amounts available under an HRA to persons with cancer Example: Employer may not offer the HRA only to employees who fail a physical examination Enrollment may not be conditioned on waiving the traditional group health plan

New Opportunities Provided by the Final HRA Regulations
July 24, 2019 Kim Wilcoxon, Partner

New Opportunities Provided by the Final HRA Regulations

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New Opportunities Provided by the Final HRA Regulations

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