Health Reimbursement Arrangement Proposed Rule (December 28, 2018)
The Church Alliance filed a comment letter on the Notice of Proposed Rulemaking published by the Departments of Treasury, Labor, and Health and Human Services (“Departments”) regarding a proposal to allow integrating health reimbursement arrangements (“HRAs”) with individual health insurance. The Church Alliance asked the Departments to consider the special circumstances of ministers who may be required by religious authorities to be offered a group health plan in harmony with denominational beliefs. The letter suggested that the Departments would need to be flexible for such situations, if they wish to enable lay employees of the denomination to select individual policies with HRAs. The Church Alliance also asked the Departments to clarify that employees, including ministers, on long-term disability, may receive HRAs that will be considered “integrated” with Medicare.