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On June 13, 2019, the Internal Revenue Service (IRS), Department of Labor and Department of Health and Human Services (HHS) issued a new regulation that is intended to increase the use of tax-favored health reimbursement arrangements (HRAs) as a means of expanding access to health insurance in the individual insurance market. One likely effect of the new regulation, which will take effect on January 1, 2020, is to make it more likely that small employers…