Effective for years beginning after December 31, 2016, small employers with less than 50 full-time and full-time equivalent employees may offer Health Reimbursement Arrangements (“HRAs”) that will not be considered “group health plans” for purposes of meeting ACA requirements. This new law means that a small employer may have a stand-alone HRA to reimburse employees for health care expenses without violating the ACA. The Departments issued ACA FAQ Part 35 on this topic.