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A wrinkly screenshot of part of the ICHRA regs If full-time, permanent workers who decline individual coverage HRAs end up qualifying for the ACA exchange plan premium tax credit, the employer could end up facing employer mandate penalty bills. (Image: Allison Bell/ALM)

Big employers that use the new individual coverage health reimbursement arrangement (HRA) programs to replace traditional group health plans for permanent, full-time workers will have to make sure the employees can afford Affordable Care Act exchange plan, according to health care and labor lawyers at Foley Hoag LLP.

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