On October 31, 2017, the IRS issued a series of questions and answers (Notice 2017-67) regarding the requirements for Qualified Small Employer Health Reimbursement Arrangements (QSEHRAs). The 59-page document contains 79 questions covering various topics with respect to QSEHRA administration and compliance. The guidance is likely to form the basis of forthcoming proposed regulations regarding QSEHRAs. The guidance applies to plan years beginning on or after November 20, 2017, and public comments will be accepted through January 19, 2018.

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