A wrinkly screenshot of part of the ICHRA regs If full-time, permanent workers who decline individual coverage HRAs end up qualifying for the ACA exchange plan premium tax credit, the employer could end up facing employer mandate penalty bills. (Image: Allison Bell/ALM)

Big employers that use the new individual coverage health reimbursement arrangement (HRA) programs to replace traditional group health plans for permanent, full-time workers will have to make sure the employees can afford Affordable Care Act exchange plan, according to health care and labor lawyers at Foley Hoag LLP.

The lawyers — Thomas Barker, Christopher Feudo and Ross Margulies — talk about the individual coverage HRA funding issue in an alert analyzing the new individual coverage HRA regulations.

The Internal Revenue Service, the U.S. Department of Labor's Employee Benefits Security Administration, and the U.S. Department of Health and Human Services published the  final regulations in June.

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Allison Bell

Allison Bell, a senior reporter at ThinkAdvisor and BenefitsPRO, previously was an associate editor at National Underwriter Life & Health. She has a bachelor's degree in economics from Washington University in St. Louis and a master's degree in journalism from the Medill School of Journalism at Northwestern University. She can be reached through X at @Think_Allison.