Reporting for, and Clearing Up Confusion Over, Post-65 Retiree Health Reimbursement Arrangements

By | Employment Matters Blog | November 3, 2015

In an earlier post, we reported on a troubling development in the draft 2015 instructions for Forms 1094-B and 1095-B which, if adopted, would have required sponsors of Health Reimbursement Arrangements (“HRA”) to issue separate Forms 1095-B and transmit on Form 1094-C when the HRA was integrated with fully-insured coverage.