News & Information



5500 Preparer's Manual for 2012 Plan Years

5500 Preparer's Manual for 2012 Plan Years
The premier resource in the field of Form 5500 preparation, 5500 Preparer's Manual will help you handle the required annual Form 5500 filings for both pension benefits and welfare benefit plans.

CCH® BENEFITS — 08/29/11

State Health Care Reform Update

from Spencer’s Benefits Reports: Health reimbursement arrangements (HRAs) have been exempted from the annual limit restrictions in the Patient Protection and Affordable Care Act (ACA) and do not need to apply individually for waivers or waiver extensions from the restrictions, according to August 19 guidance from the Center for Consumer Information and Insurance Oversight (CCIIO).

In June, CCIIO announced that limited benefit plans have until Sept. 22, 2011, to apply for or renew a temporary waiver from the annual limit restrictions. The CCIIO already has granted waivers to more than 1,500 plans (see below).

In the most recent guidance, the CCIIO noted that “all HRAs set limits on the amount that can be spent and, we believe, those limits would always be less than the applicable restricted annual limit amounts. Accordingly, applying the restrictions on annual limits … to HRAs would result in a significant decrease in access to HRA benefits. Therefore, this guidance exempts as a class all HRAs that are subject to the requirements of [ACA Sec. 2711] and that were in effect prior to Sept. 23, 2010 from having to apply individually for an annual limit waiver for plan years beginning on or after Sept. 23, 2010 but before Jan. 1, 2014.”

If an employer that maintains an HRA also maintains other coverage, whether or not that coverage is integrated with the HRA, that other coverage must meet the annual limit requirements or obtain a waiver.

An HRA that is exempt from an annual limit still must comply with the record retention and annual notice requirements to participants and subscribers set forth in the supplemental guidance issued in June. For instructions on these requirements for HRAs, visit to the “Technical Instructions for the Waiver Extension and Waiver Application Process,” available at

Waivers Granted

By the end of July, the CCIIO had provided 1,472 one-year waivers and 106 three-year waivers to organizations covering more than 3.4 million employees. By the end of June, 1,471 plans had received waivers.

By type of applicant, the waivers granted so far are, as follows:

For more information, visit

For more information on this and related topics, consult the CCH Pension Plan Guide, CCH Employee Benefits Management, and Spencer's Benefits Reports.

Visit our News Library to read more news stories.