The IRS on Wednesday released Notice 2015-17 addressing additional questions on employer payment plans and providing limited transitional relief for small employers who are currently reimbursing employees for individual health insurance premiums.  

The IRS offered answers to five questions, adding to an ever-growing body of regulatory guidance on this topic. Beginning with Revenue Ruling 61-146 through the most recent guidance issued in 2013 and 2014, they continue to emphasize that any reimbursement of individual premiums by an employer, whether on a pre-tax or after-tax basis, is an employer payment plan (EPP). These EPPs are considered group health plans when there is more than one eligible employee entitled to reimbursement. This connection between EPPs and group health plans is critical because the three agencies (IRS, HHS and DOL) view the Affordable Care Act’s market reforms to apply to all group health plans.   

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