The IRS issued Notice 2017-20, which provided welcome relief for employers who have chosen to move forward in implementing qualified small employer health reimbursement arrangements (QSEHRAs). In general, QSEHRAs allow small employers that meet certain criteria to offer a health reimbursement arrangement, which can provide for reimbursement of individual premiums. While we’ve previously covered the available statutory details related to QSEHRAs, there are still a number of questions facing employers and brokers.
One of the requirements for employers choosing to offer a QSEHRA is that the employer must provide notice to eligible employees. The statute provided deadlines for notice distribution, but was scarce on the information required to be included in the notice. In Notice 2017-20 the IRS acknowledged the need for greater detail and indicated it was prepared to issue such guidance in the near future. In the meantime, the IRS extended the previous March 13th deadline to not less than 90 days following the issuance of applicable guidance.
Additionally, the IRS stated, “Employers that furnish the QSEHRA notice to their eligible employees before further guidance is issued may rely upon a reasonable good faith interpretation of the statute to determine the contents of the notice.”
Despite remaining questions, this notice from the IRS will likely provide some welcome reassurance for brokers and employers that have begun implementing QSEHRAs.
For more information, contact Cornerstone today.