What is an HRA?

A Health Reimbursement Arrangement, or HRA, is an employer-funded arrangement that reimburses employees for certain medical expenses determined by the employer. These expenses include, but are not limited to co-pays, coinsurance and deductibles incurred by employees, and if the employer so chooses, their spouses and dependents.

When combined with a high-deductible insurance plan, HRAs can help lower insurance premiums for the employer because of the increased deductible. Employees are not paying for this increased deductible because HRA funds typically match the increase in deductible.

In implementing an HRA, employers create an account for each participating employee and reimburse the employee for medical expenses incurred up to his or her account balance. An HRA must be paid for solely by the employer and may not be funded through employee salary reductions. It is at the employer's discretion to roll over unused funds in an employee's account to subsequent coverage periods.

There is no specific code section governing HRAs, but the IRS has confirmed their tax-favored treatment under the general principles of Code 105 and 106. However, IRS Notice 2002-45 does govern the HRA and defines it as "an arrangement that:

The Benefits of an HRA

If an HRA is operated in compliance with IRS guidance, employees will not be taxed on the value of their HRA coverage or on reimbursements that they receive from the HRA. The money placed in the HRA is not subject to FICA contributions by either the employer or employee. Additionally, money in the plan is never subject to Federal or State Income Tax as long as it is used exclusively to reimburse the employee and/or their dependents for eligible healthcare expenses as determined by the employer.

Debit Cards

With the use of the Bentley-Yates sponsored Benny™ Prepaid Benefits Card, employees will no longer have to wait on their HRA money. Rather than having to fill out claims forms and waiting on manual checks, Participants will receive preloaded debit cards giving them instant access to their funds at the point of service, eliminating the need for employees to pay cash for eligible expenses and without having to submit a Claims Form. The Employee will be able to monitor his/her spending by logging on to a dedicated web site. Read more about this advanced service here!

Financial Value

Premium Decrease: Employers can decrease their medical premium expense by moving to a high-deductible plan, while at the same time providing insulation for employees from higher health costs.

Contribution Amounts: Amount of individual and family HRA funding is at the employer's discretion.

Rollover Amounts: The employer has potential to keep unused funds at the end of the plan year or allow funds to roll over from year to year.

HRA Plan Designs

We at Bentley, Yates & CO can tailor an HRA plan to fit the unique needs and requirements of your company. Common HRA plan designs include:

Flexibility of the Bentley, Yates HRA plan can best be illustrated by a few simple drawings.

The main objective of an HRA is to fund the Group Medical Plan (GMP) Deductible:

This GMP deductible can be funded partly by the employee via the so-called HRA deductible and partly by the employer through an HRA plan:

The HRA can again be flexible by defining a split in funding between the employer and the employee for example 50/50 or 20/80:

Finally, the Bentley, Yates HRA can be made even more sophisticated by the facility to 'slide' the HRA within the GMP deductible, i.e. defining an amount of the GMP deductible to be fully funded by the employee after the HRA has been exhausted:

The Bentley, Yates experts will work with you to find the optimum combination of benefits for your company's HRA.

A Closer Look at the HRA Features

The Bentley, Yates HRA helps you and your company and employees manage your healthcare and related expenses:

HRAs and COBRA

An HRA is a group health plan subject to COBRA continuation requirements. A participant electing COBRA coverage must be eligible to receive the maximum amount of reimbursement that was otherwise available at the time of the COBRA qualifying event. The amount available must be increased at the same time and in the amount as any increase for similarly situated non-COBRA beneficiaries. In addition, the COBRA premium may not differ for similarly situated COBRA beneficiaries, regardless of the dollar amount available to each individual.

Coordination with Flexible Spending Accounts

An employer may offer both an FSA and an HRA, but expenses cannot be reimbursed under both the HRA and the FSA. In the plan documents, employers specify which account must reimburse first; typically, the HRA pays first and the FSA second, but it is at the discretion of the employer. FSAs and HRAs can also be structured so that specific types of items can only be reimbursed from one or the other, for example, permitting the FSA to cover only vision expenses and permitting the HRA to cover all other forms of medical expense.

Relevant links to more HRA Information

Governing HRA IRS link:
http://www.irs.gov/pub/irs-drop/n-02-45.pdf

HRA and FSA descriptions:
http://www.irs.gov/publications/p969/ar02.html#d0e1691

"Health Reimbursement Arrangements - A cutting
edge tool for health insurance cost management"
By Leo J. Vidal, J.D., M.A., CPA:
https://www.utea.org/educatorResources/healthInsurance/...

Health Reimbursement Arrangements - Notice 2002–45
By Lorianne D. Masano of the Office of
Division Counsel/Associate Chief Counsel
(Tax Exempt and Government Entities):
http://www.unclefed.com/Tax-Bulls/2002/not02-45.pdf

Other relevant Links:
FSA Information
COBRA Information

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