NASE Submits Comment Letter in Support of HRA Regulations

Monday, January 28, 2019

In the waning days of 2018, the National Association for the Self-Employed submitted comments in support of rules around health reimbursement arrangements (HRAs) that are being proposed by the U.S. Departments of the Treasury, Labor, and Health and Human Services.

The NASE has long championed and advocated for a reversal of treatment of Health Reimbursement Arrangements that were implemented by the previous Administration. We have advocates strongly in the belief that the self-employed and micro-business owners should have as many tools available to them to deal with rising health care costs and having access to HRAs is essential to ensuring that all Americans can have affordable health care.

With the vast majority of Americans, roughly 180 million, receiving health care through an employer-sponsored system, the self-employed and micro-business business owners have largely been unable to offer coverage to their employees due to costly burdensome requirements and mandates, resulting in them being unable to offer health care benefits, in any form. In fact, the number of small businesses offering group health insurance has declined by 25 percent since 2010. Currently, less than half of small businesses offer any kind of health insurance to their workers. The smallest of businesses are being treated unfairly in the current marketplace, however, the opportunity for a small employer to offer and a self-employed individual to benefit from an HRA for the purchase of individual health coverage (IHC) will help millions of businesses offer a meaningful benefit to their employees.

The comment letter further stated NASE’s support for allowing an employee to fund an HSA that can be used with an HSA-compatible policy purchased with HRA funds. We requested that the Departments provide clarity in that an HRA that does not provide reimbursement for out-of-pocket expenses is compatible with a health savings account (HSA).

We look forward to quick action by the Departments of Treasury, Labor, Health and Human Services, in issuing the final rule.

Katie Vlietstra is NASE’s Vice President for Government Relations and Public Affairs

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