Proponents of consumer-driven health care have long advocated for Health Care Reimbursement Arrangements, where employers provide a sum of money to their employees to purchase coverage in the individual health insurance market without any further employer oversight or involvement. Beginning in 2014, this approach to consumer-driven health care will run afoul of the ban on annual limits imposed by the Patient Protection and Affordable Care Act. However, in 2014, the health care reform act’s employer-shared responsibility rules come into play, and by wrapping the employer contribution, if any, into a group market insurance product, private exchanges seek to address these and other issues.

Alden J. Bianchi of Mintz Levin’s Employment, Labor & Benefits Practice Section, recently published a Client Alert that is a must read for those who follow – or should follow – this important topic.