On Feb. 27, 2017, the Internal Revenue Service (IRS) issued Notice 2017-20 to extend the deadline for small employers to provide the initial employee notice for a qualified small employer health reimbursement arrangement (QSEHRA). QSEHRAs are a new benefit option for eligible small employers, effective for plan years beginning on or after Jan. 1, 2017.
Employers that adopt QSEHRAs are usually required to provide a written notice to eligible employees at least 90 days before the beginning of the plan year. As transition relief, small employers had until March 13, 2017, to provide the initial QSEHRA notice. The IRS plans to issue guidance in the near future regarding the content requirements for the QSEHRA notice. Until then, employers are not required to provide the initial QSEHRA notice.
ACTION STEPS
Small employers that adopt QSEHRAs for 2017 have additional time to provide the initial QSEHRA notice. Rather than providing the notice by March 13, 2017, small employers can wait to provide the notice until after the IRS issues its guidance on the notice’s content requirements. In the meantime, employers that provide the initial QSEHRA notice may rely upon a reasonable good faith interpretation of the law’s content requirements for the notice
