Notice for Health Reimbursement Arrangements Integrated with Individual Health Insurance Coverage

ICR 202503-1210-003

OMB: 1210-0160

Federal Form Document

Forms and Documents
Document
Name
Status
Supporting Statement A
2025-05-22
ICR Details
1210-0160 202503-1210-003
Received in OIRA 202204-1210-003
DOL/EBSA
Notice for Health Reimbursement Arrangements Integrated with Individual Health Insurance Coverage
Extension without change of a currently approved collection   No
Regular 06/04/2025
  Requested Previously Approved
36 Months From Approved 06/30/2025
1,415,083 2,140,197
32,035 53,131
16,996 24,831

On June 21, 2018, the Department published the Definition of Employer under Section 3(5) of ERISA—Association Health Plans final rule. On August 3, 2018, the Department of Labor, HHS and the Treasury Department (the Departments) published the Short-Term, Limited-Duration Insurance final rule. These final rules remove the prohibition on integrating health reimbursement arrangements (HRAs) with individual health insurance coverage, if certain conditions are met. The final rules also set forth conditions under which certain HRAs are as limited excepted benefits. In addition, the Treasury Department and the IRS finalized rules regarding premium tax credit (PTC) eligibility for individuals offered coverage under an HRA integrated with individual health insurance coverage, and DOL finalized a safe harbor to provide HRA plan sponsors with assurance that the individual health insurance coverage that is integrated with an HRA would not become part of an ERISA plan if the conditions of the safe harbor are met. Finally, HHS finalized rules that provide a special enrollment period in the individual market for individuals who gain access to an HRA that is integrated with individual health insurance coverage or who are provided a qualified small employer health reimbursement arrangement (QSEHRA). The following five information Collections are contained in the final rules: (1) Verification of Enrollment in Individual Coverage; (2) HRA Notice to Participants; (3) Notice to Participants that Individual Policy is not Subject to Title I of ERISA; (4) Participant Notification of Individual Coverage HRA of Cancelled or Discontinued Coverage; (5) Notice for Excepted Benefit HRAs. These information collections notify the HRA that participants are enrolled in individual health insurance coverage, help individuals understand the impact of enrolling in an HRA on their eligibility for the PTC, and help individuals understand that coverage is not subject to the rules and consumer protections of the Employee Retirement Income Security Act (ERISA).

US Code: 29 USC 2510 and 2590 Name of Law: Employee Retirement Income Security Act of 1974 (ERISA)
  
None

Not associated with rulemaking

  89 FR 56416 07/09/2024
90 FR 2371 06/04/2025
No

  Total Request Previously Approved Change Due to New Statute Change Due to Agency Discretion Change Due to Adjustment in Estimate Change Due to Potential Violation of the PRA
Annual Number of Responses 1,415,083 2,140,197 0 0 -725,114 0
Annual Time Burden (Hours) 32,035 53,131 0 0 -21,096 0
Annual Cost Burden (Dollars) 16,996 24,831 0 0 -7,835 0
No
No
The Department has updated the wage rates and the data inputs regarding the number of individuals enrolled in ICHRAs, as well as the number of employers offering HRAs. The forecasted number of enrollees are lower in this submission than in the prior information collection. As a result, the number of responses decreased by 725,114, the hour burden decreased by 21,096 hours, and the cost burden decreased by $7,835.

$0
No
    No
    No
Yes
No
No
No
James Butikofer 202 693-8434 Butikofer.James@dol.gov

  No

On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
 
 
 
 
 
 
 
    (i) Why the information is being collected;
    (ii) Use of information;
    (iii) Burden estimate;
    (iv) Nature of response (voluntary, required for a benefit, or mandatory);
    (v) Nature and extent of confidentiality; and
    (vi) Need to display currently valid OMB control number;
 
 
 
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
06/04/2025


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