Health reimbursement account


Health Reimbursement Account is an incorrect, but commonly used name for a Health Reimbursement Arrangement, a type of US employer-funded health benefit plan that reimburses employees for out-of-pocket medical expenses and, in limited cases, to pay for health insurance plan premiums.
An HRA, in fact, is not an account, since money is not saved in a singular location. Instead, HRAs function as an arrangement between employer and employee. In the arrangement, an employee purchases health insurance, or makes an eligible out-of-pocket expense before submitting proof of purchase to the employer so they can reimburse the employee, tax-free.
Following implementation of the Affordable Care Act, the health plans must be integrated with a qualified employer-sponsored group health insurance plan to avoid excise tax penalties. Using a Health Reimbursement Arrangement yields "tax advantages to offset health care costs" for both employees and employers.

QSEHRA

In 2016, qualified small employer HRA were created which allows small employers to pay for premiums, including on the individual market such as through a health insurance marketplace, although the employees may not be eligible for subsidies. On average, employers with these plans offered an average $387 per month.

ICHRA

In January 2020, a new type of HRA will be available to businesses of all sizes that allows an employer to scale its benefits across nine different classes. This new tax-advantaged tool is called an ICHRA and will bring greater flexibility in design, expand upon the benefits that its predecessor, the QSEHRA, offered, and present a potential solution to the issue of premium tax credits and HRA benefits that QSEHRAs posed.
An ICHRA allows employers to reimburse their employees tax-free for individual insurance and medical expenses. No more hassling with renewals, participation rates, stressing about doctor networks, or getting constant annual increases—just decide which benefits go to which classes of employees, set monthly allowance for each, and it's done. Employees get to choose any plan they want and flexible design criteria allows employers to customize their ICHRAs to suit their needs.

Establishment

Health Reimbursement Arrangements are funded solely by the employer; they cannot be funded through employee salary deductions. The employer sets the parameters for the Health Reimbursement Accounts, and unused dollars remain with the employer: they do not follow the employee to new employment.

Contributions

Health Reimbursement Accounts are notional accounts; no funds are expensed until reimbursements are paid. By health reimbursement arrangements, employers reimburse employees directly only after the employees incur approved medical expenses. According to the IRS, an HRA "must be funded solely by an employer. Contributions cannot be paid through a salary reduction agreement. There is no minimum or maximum contribution limit on the employer's contributions to an HRA.

Distributions

According to the IRS, employees are reimbursed tax-free for qualified medical expenses up to a maximum amount for a coverage period. HRAs reimburse only items agreed to by the employer that are not covered by the employer's selected standard insurance plan. The arrangements are described in IRC Section 105.
With an HRA, employers fund individual reimbursement accounts for their employees and define what those funds can be used for, specified out-of-pocket expenses such as deductibles and co-pays.
Qualified claims must be described in the HRA plan document at inception: before reimbursing employees for the medical expenses. Arrangements may vary from plan to plan, and an employer may have multiple plans in place, allowing much flexibility. The kinds of expenses that can be paid under an HRA are generally the same as the expenses that can be paid through a Flexible Spending Account.
The employer is not required to prepay into a fund for reimbursements. Instead, the employer reimburses employee claims as they occur.
Reimbursements under an HRA can be made to the following persons:
  1. Current and former employees.
  2. Spouses and dependents of those employees.
  3. Any person the employee could have claimed as a dependent on the employee's return unless:
  4. # The person filed a joint return,
  5. # The person had gross income of $3,400 or more, or
  6. # The employee or spouse, if filing jointly, could be claimed as a dependent on someone else's tax return.
  7. Spouses and dependents of deceased employees.

    Advantages

Advantages of HRAs for employers include:
Advantages of HRAs for employees include:
A frequent complaint regarding HRA arrangements is that they are extremely opaque in regards to their requirements. HRAs must follow "a variety of statutory rules and provisions" including the COBRA continuation coverage requirements, ERISA, and HIPAA.
HRA plans are considered "Primary Payers" subject to Medicare Secondary Payer mandatory reporting requirements. There are significant penalties for failure to comply with the MSP reporting requirements. Although the MSP reporting requirements began to apply to certain group health plans on January 1, 2009, CMS has delayed mandatory reporting for HRAs.
Rules pertaining to their reimbursements are perceived by member participants to be somewhat contradictory and/or even incoherent, leading some to lose contributions intended for healthcare but later to be disallowed.
Other disadvantages of HRAs include:
A sole proprietor can employ a spouse who actually helps the business. The employer would need to establish a W-2 to make the spouse's employment legitimate. The health care can be run through the business and save the family, on average, $3,000 each year. As small businesses look to reduce costs, especially medical, the HRA can be a great tool that has been used by all too few since the 1954 tax law.
HRAs are treated as group health plans and subject to the Medicare secondary payment. HRAs are subject to the provisions regardless of whether or not they have an end-of-year carry-over feature.
Standalone HRAs not offered in conjunction with a High Deductible Health Plan are subjected to restrictions starting in 2014. The law now essentially bans the existence of most such HRAs, as a health plan with maximum benefit limit.