Key HRA Decision Points

If you are an employer considering implementing health reimbursement accounts or high deductible health plans with HRAs, you should consider several things first, including your objectives and possible plan designs. Below are questions to think about.

Determining company objectives

Evaluate your objectives for your benefits package and how HDHP/HRAs contribute to your goals.

• Is your primary goal to save money on health costs or to move toward employee-driven healthcare decisions?
• What is your strategic timeline for making these changes?
• Do you have existing educational resources to help employees understand the effects of healthcare premium costs on your business?
• How will your choice of healthcare plans affect your employee recruitment and retention efforts?
• What is your corporate culture today and how well does your organization embrace change? Company characteristics that influence the ability to introduce HRAs include a paternalistic culture, high turnover, communication ability and recent major changes in workforce or benefits.
• What employee characteristics make employees more interested in one approach over another? Age, gender, time at company, personal situations, number of dependents or salary? How well do you know what your employees want?

Nine key plan design questions

You should also consider different aspects of plan design before implementing an HDHP/HRA.

1. How should you offer an HRA with other group health coverage?

• Stand-alone HRA
  • Due to the Affordable Care Act’s market reforms, most stand-alone HRAs are prohibited.
  • Retiree-only HRAs qualify for an ACA exemption and are still permitted.
  • Special stand-alone HRA designs (qualified small employer HRAs and individual coverage HRAs) allow employers to reimburse individual health insurance premiums, subject to specific design requirements.
•  HDHP/HRA design
  • High flexibility
  • Employer can limit the availability of HRA COBRA coverage to qualified beneficiaries who also elect HDHP COBRA coverage.
  • Under the ACA, most HRAs must be integrated with other group health plan coverage (i.e., HDHP coverage).
• Two types of integration methods — one method imposes a “minimum value” condition on the non-HRA health plan coverage; the other limits the types of expenses that may be reimbursed under the HRA. Under both integration methods:
  • The employer sponsoring the HRA must offer a group health plan (other than the HRA) that does not consist solely of excepted benefits (i.e., an HDHP).
  • Employees receiving the HRA must actually be enrolled in another group health plan that does not consist solely of excepted benefits.
  • The HRA must be available only to employees who are actually enrolled in another group health plan.
  • Employees must be offered the opportunity to permanently opt out of and waive future reimbursements from the HRA annually and upon termination (if the HRA is not forfeited when employment terminates)

2. Who is eligible to participate?

• As long as the HRA passes nondiscrimination testing and the ACA’s integration requirements (if applicable), employers have flexibility when it comes to establishing the HRA’s eligibility rules.

3. What expenses are reimbursable?

• If an HRA is offered with an HDHP/HSA, HRA coverage must be limited to certain expenses, such as preventive care, or designed to permit reimbursements after the HDHP deductible has been met.
• An HRA’s reimbursable expenses are limited to qualified medical expenses; however, an employer may choose to be more restrictive on what the plan will reimburse.
• Also, if the ACA’s minimum value integration method is not used, reimbursements may be limited to copayments, coinsurance, deductibles and premiums under the non-HRA group coverage, as well as medical care that does not qualify as “essential health benefits.”

4. How much will the employer contribute?

• There is no specified cap on the amount an employer can contribute to an HRA. Employer contributions do not have to be the same for all employee groups (for example, individual coverage, family coverage) provided the plan complies with nondiscrimination rules.
  

5. How will the HRA be funded?

• HRAs must be funded solely by the employer. Typically, reimbursements will be made from an employer’s general assets.
  

6. Are carryovers allowed?

• HRAs may allow carryovers of unused account balances, but they don’t have to. Employers can allow unlimited carryovers or put limits on carryovers.

7. How are reimbursements processed?

• Since substantiation is required for HRA reimbursements, and because of privacy concerns, employers may consider hiring a third-party administrator to substantiate claims. Employers should complete a due diligence of TPAs and have service agreements and business associate contracts reviewed by counsel. Employers should also consider if they want to cap reimbursements. If the employer also sponsors a health FSA, consider how the claims will be ordered.

8. Design employee communication, education and support tools.
9. Adopt a plan document and distribute a Summary Plan Description to employees.

For more information about employee benefits,our services and products, contact HANYS Benefit Services by email or call 800.388.1963.

This is not intended to be exhaustive nor should any
discussion or opinions be construed as professional advice. © 2023 Zywave, Inc.
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