CMS Seeks Comments on Routine Data Collection Plans
Published Date: 5/15/2026
Notice
Summary
The Centers for Medicare & Medicaid Services (CMS) wants your thoughts on their plan to collect some info from the public. They’re asking for comments by July 14, 2026, to make sure the process is clear, useful, and not too much work. This affects anyone who might provide info to CMS and helps keep things running smoothly without wasting time or money.
Analyzed Economic Effects
4 provisions identified: 2 benefits, 2 costs, 0 mixed.
Employees Can Use HRAs for Premiums
The 2019 regulations (effective for plan years beginning January 1, 2020) allow employers to offer individual coverage Health Reimbursement Arrangements (HRAs) and let employees use HRA amounts to pay medical expenses, including premiums for individual health insurance and Medicare.
Required Notices for Excepted-Benefit HRAs
Non-Federal governmental plan sponsors offering excepted-benefit HRAs must provide a notice describing eligibility rules, annual or lifetime caps or other limits, and a description or summary of benefits no later than 90 days after an employee becomes a participant and annually thereafter.
Paperwork Burden on Government Employers
CMS is extending the information collection (Form CMS-10704, OMB Control Number 0938-1361) related to HRAs; the affected public is State, Local, or Tribal governments with 6,354 respondents, 1,347,048 total annual responses, and 3,136 total annual hours.
Substantiation Requirement for Individual HRAs
The information collections associated with the 2019 HRA regulations include substantiation requirements for individual coverage HRAs (referenced at 45 CFR 146.123(c)(5)), meaning participants or sponsors must provide information to substantiate HRA coverage or eligibility.
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Key Dates
Department and Agencies
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