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Following issuance of the final HRA rule, the Department of Treasury and the IRS released proposed rules governing how this new structure interacts with the employer mandate and other safe harbor provisions. The rule now permits HRAs to be integrated with individual health coverage for purposes of complying with specific ACA provisions.

The final HRA rule is generally applicable as of January 1, 2020 and taxpayers may rely on the interim employer mandate and safe harbors until six months after those final rules are published. You can read the memo in full here.

Comments are due on the proposal by December 30, 2019. If you’d like to submit a comment, please contact Joel Wood at or Joel Kopperud at