July 2026: Q&A Roundup — HRA PCORI Fees, Qualifying Events for Dependent Coverage, and COBRA for Holding Companies

  • July 22, 2026
  • Posted by: Gus Altuzarra
  • Category: Compliance Q&A
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hra health plan

7.2.26  |  COBRA FOR HOLDING COMPANY


Q. Our client, a holding company with 12 employees, owns a subsidiary with more than 50 employees. They operate under different tax IDs. The holding company does not offer COBRA, but the subsidiary does offer COBRA. The holding company is looking for a compliant solution that they can offer to employees who leave the company. Can COBRA still be offered even if the holding company has fewer than 20 employees?
A. If the holding company owns all of the subsidiary, the two companies are treated as one for COBRA purposes. This means that the holding company must comply with COBRA with respect to their 12 employees. This is not optional, it is mandatory.

 

7.9.26  |  QUALIFYING EVENT QUESTION

Q. An employee’s 23-year-old dependent wants to leave the parent’s health plan and enroll in the dependent’s employer plan effective Jan. 1. The parent’s plan renews on July 1. Should the parent drop the dependent from the parent’s plan effective June 30, creating a qualifying event for the dependent to enroll in their employer’s plan on July 1? Or should the dependent wait until Jan. 1 to enroll in their employer’s plan, creating a qualifying event for the parent to drop the dependent from their plan at that time?
A. Either option should work. If the dependent is dropped from the parent’s plan during the parent’s open enrollment, this should be a qualifying event allowing the dependent to enroll mid-year in their employer’s plan. Likewise, the dependent can enroll in their employer’s plan at their open enrollment, and this will be a qualifying event entitling the parent to drop the dependent mid-year.
 
 
7.16.26  |  HRA PCORI FEES

Q. Does an employer with fewer than 20 employees that offers an HRA with a fully insured small employer plan need to file and pay PCORI fees for the HRA?
A. Yes, the employer must pay the PCORI fees for the HRA. There is a limited exception for HRAs with self-insured group medical plans, but this exception does not apply to HRAs with fully insured medical plans.
 
 
 
Answers to the Question of the Week are provided by Kutak Rock LLP. Kutak Rock provides general compliance guidance through the UBA Compliance Help Desk, which does not constitute legal advice or create an attorney-client relationship. Please consult your legal advisor for specific legal advice.


Author: Gus Altuzarra
Gus is the CEO of Aston Sharp Insurance Services. In 2012, Gus founded Aston Sharp to start offering a larger scope of insurance products to his clients. With extensive history in life, disability, and long-term care planning, Gus acts as a full service insurance advisor. Gus initially started working with group employers offering assistance with the new changes mandated by the ACA (Affordable Care Act). The in-flow of new technology in recent years has created an opportunity to revolutionize an outdated industry. Gus now works to consolidate Employee Benefits, HR, Payroll, Work Comp, and ACA compliance all under one roof – delivering an easy-to-use technology driven solution to his clients.

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