April 6, 2020 - NFP CARES Act Webinar CARES Act Webinar - NFP - Final | Page 42

FFCRA – Health Insurance Portion of the Credit
1. Qualified health plan expenses” paid by employer count. Act
§§7001(d) and 7003(d).
• Defined under §5000(b)(1).
Very broad, includes self-insured plans.
Includes pre-tax salary contributions (Cafeteria Plan) (after-tax
contributions don’t count). FAQ 31.
2. Amounts must be excludible by recipient under §106.
3. Allocation:
• Portion properly allocated → sick/family leave wages for which
credit is allowed.
• Methods to allocate:
Any reasonable method. FAQ #33
4. This would not include Eligible Employer contributions to HSA.
5. The amount of Qualified Health Plan Expenses may include
contributions to an HRA (including an individual coverage
HRA).
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