ACA - HRA plan for retirees-only aged 50+
EBS 12.2.6: We have an HRA plan that can only be used by retirees who have reached the age of at least 50 years old. Our jurisdiction contributes an amount to the HRA plan each pay period until the employee retires. The employees cannot use it until they retire and have reached the age of 50+; then they can start drawing from the plan. Does anyone know if this plan for retirees has to be reported as part of the ACA mandate?
I know the anticipated 2020 ACA patches has some functionality for this but until it's released, we're not sure how to handle this.