Tag: HRA

On October 12, 2017, President Trump issued an Executive Order directing the Departments of Labor (DOL), Health and Human Services (HHS), and Treasury to develop new rules to allow some exemptions from the Affordable Care Act (ACA). The Order indicates the Administration’s priorities although it has no immediate effect since any rule changes must first…

Question: Can a health reimbursement account (HRA) plan have two classes of employees with two different allocations? Can the HRA contribution be different depending on which plan the employee is enrolled in if the plans have different deductibles? Answer: The answer to both of your questions is generally yes, provided that the plan does not discriminate in…

Question: Does a large group employer have to pay PCORI fees on a medical expense reimbursement plan (MERP) for their employees and if so, is it based on participants or enrolled employees? Answer: Health reimbursement arrangements (HRAs) and medical expense reimbursement plans (MERPs) are self-funded group health plans and are subject to the PCORI fee unless…

Question:  Should Self-Funded plans that have been consolidated on one 5500, which covers the calendar year with plans with varying start and end dates, be filed all together for PCORI or filed separately according to each of their plan year start dates? Answer:  It is our understanding that the PCORI fees are based on plan…

The following question recently came from one of our clients requesting our assistance to better understand and manage this issue. Question:  We would like clarification regarding the PCORI fees that are due July 31st.  What plan years apply to this year’s payment and how do we count the total amount due?  Answer: We have had a number…

Question: For SBCs, how should an employer draft an SBC for an HRA plan specifically?  Has the DOL provided a sample SBC for the HRA? Answer: Unfortunately, the DOL has not provided a specific template for HRAs, and some HRAs do not require SBCs.  Generally, Health Reimbursement Arrangements are considered to be group health plans,…

Question:  Can you please explain the new health care reform “fee” on HRA plans to fund medical research and how it works, what it costs and how it will be paid? Answer: The “fee” you are referring to related to health care reform is the one placed on health plan carriers (for fully insured plans) and…

Question: For a self-insured employer that offers medical coverage and an HRA as part of its plan, does the CER fee apply to both the medical insurance and the HRA separately (meaning they pay the fee twice?) or is it assessed against them as a single unit, meaning they pay the fee of just $1?…

Question: Are SBC’s required for all lines of coverage or just medical? Answer: The requirements for SBCs(Summaries of Benefits & Coverage) under health care reform apply to group health plans.  If you are unclear as to whether a plan meets the criteria for group health plans, discuss it with your benefits broker or attorney.  Here…

Question:  A client offers an HRA. If an employee has a prescription that is not covered by the group health plan, can the HRA reimburse it? Answer: Generally, prescription drugs and medicines are considered qualified medical expenses eligible for tax-favored treatment when reimbursed under an employer HRA, and non-prescription medicines (other than insulin) are not…