White Paper

Curing What Ails You – Relief for Small Employer HRAs


The impact of the ACA on HRAs has not been favorable.

In companies across the U.S, employers either eliminated their HRAs or integrated them with a major medical plan in order to avoid significant penalties under ACA. The rules imposed a significant burden on small employers as many of those employers used HRAs to reimburse employees for the cost of individual health insurance policies they purchased rather than sponsor a group health plan. While there was limited relief granted through June of 2015, the real relief came at the end of 2016 with the 21st Century Cures Act.



Nancy K Campbell, Esq.

Snell & Wilmer L.L.P.

Nancy K. Campbell, Esq., is a partner in Snell & Wilmer L.L.P.’s Phoenix office. Ms. Campbell has been practicing law in the firm’s Employee Benefits and Executive Compensation Group since September 1992 and advises a diverse group of clients on employee benefit issues, including qualified plan and welfare plan design, administration and compliance, and executive compensation. She was selected by her peers to be included in The Best Lawyers in America in 2007 and 2008. Ms. Campbell is a past president of the Western Pension and Benefits Conference’s Phoenix Chapter. She is the chair of the Cafeteria Plans and Reimbursement Accounts Subcommittee of the Employee Benefits Committee of the Tax Section of the American Bar Association. Ms. Campbell graduated with high distinction from The University of Iowa College of Law and The University of Michigan School of Business Administration.

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