Late Friday, the Dept. of Labor (DOL) and the Internal Revenue Service (IRS) issued guidance on how the annual limit and preventive services rules will apply to the Patient Protection & Affordable Care Act (PPACA). IRS Notice 2013-54 and DOL Technical Release 2013-03, which mirror each other, specifically address what type of HRAs, FSAs and other employer healthcare arrangements will/will not be considered compliant as of January 1, 2014.
TASC Governmental Affairs is currently reviewing this complicated guidance to assess the effect on our products and services. We will communicate further on this topic in the near future.