afa59010_ered_Life__Among_Other_Changes__Comments
[Benefit Type] HRA [Does Reinsurance Fee Apply?] Results will vary. An HRA usually does not constitute an "excepted benefit" so that exception typically would not be available. However, no Reinsurance Fee applies if an HRA is "integrated" with a major medical coverage. [Comments] 
Although several pieces of federal guidance discuss special rules for "integrated" HRAs, no guidance has yet defined the term. A "non-duplication" rule can reduce (or eliminate) an amount owed with respect to an HRA, if the employer also maintains a separate self-insured health plan. The non-duplication rule is discussed below.
Employers, Insurers Face New “Reinsurance” Fee of $63 Per Covered Life, Among Other Changes
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