White Paper

7 Pages
  • 7 Pages

Zombie Benefits – Are Health Reimbursements Arrangements (HRAs) Back From the Dead?


HRAs haven't been treated kindly by the ACA.

Plenty of employers eliminated HRAs, or combined them with a major medical plan, so that they would dodge serious penalties under the ACA. In fact, at one point it seemed as if the after-tax HRAs did not have to comply with the ACA. However, that is not the case, as the IRS stated that even after-tax HRAs are subject to the ACA rules. This white paper reviews two different types of HRAs and other important changes.



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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