Every employer who offers health benefits struggles with ever increasing
costs. Higher premiums must be absorbed or passed on to employees, who
balk at the reduction in take home pay. One solution to this problem can
be found in a Health Reimbursement Arrangement or HRA. It is a form of
defined contribution health plan that can not only reduce plan premiums but also
encourage employees to manage health care costs more efficiently.
HRAs are
straightforward. They can only be used to reimburse substantiated medical
expenses incurred by the employee or the employee’s spouse or dependents during
the plan year. They are funded entirely by employer contributions. Hence,
they must be kept separate from any cafeteria or flex plan benefit that entails
an employee salary reduction agreement. However, unlike a cafeteria plan
“use it or lose it” limitation, unused balances in an HRA account can be rolled
over into the next plan year. Employees will like this feature. Employees
who husband their HRA can build an account balance that will serve as a cushion
against unexpected doctors’ bills or be used to pay for anticipated but
significant medical expenses that are not otherwise covered by insurance.
Unused HRA balances can even be used by former employees to help transition into
retirement or a new job.
At first glance, HRAs might not seem all that appealing to an employer
since it must bear the full cost. The trick here is to see the big
picture. Although it can be a stand alone benefit that will be very
attractive to employees, an HRA can also be used together with a plan providing
high deductible health coverage to reduce employer costs. Since premiums
for high deductible health coverage can be significantly lower, the employer can
even use some of the savings to fund employee HRA accounts. This could not
only curb those constant premium increases, but also help stabilize this
volatile cost of doing business.
Naturally, there are special IRS
rules that govern the use of HRAs. In order to ensure that the benefit is
a deductible business expense—and is excludable from employee income—, HRAs can
only be used to reimburse substantiated medical expenses. However, this
could include payments for vision and dental care and even health insurance
premiums. Salary reduction arrangements cannot be used directly or
indirectly to fund HRA accounts. This can be tricky if a cafeteria plan is
used to pay for high deductible health coverage that is commonly used in
conjunction with an HRA account. However, proper planning can avoid this
result and preserve the favorable tax treatment conferred on HRAs.
An HRA cannot be used to reimburse the same expenses as those that are
reimbursable under a salary reduction funded health Flexible Spending Account
(FSA). This usually means that the health FSA account must be used up
before the HRA account can be tapped to reimburse the same covered
expense. HRAs are also ERISA plans, and they must be offered as part of
any COBRA continuation coverage. Finally, unused HRA balances cannot be
cashed out or used as the basis for severance payments to departing
employees.
HRAs can be a valuable management tool. They offer an employer an
opportunity to reduce health care costs by combining the HRA with a lower
premium high deductible health plan. HRAs also encourage employees to
manage their accounts in ways that minimize medical costs and build unused
balances that can be carried forward from year to year for either unanticipated
expenses or planned medical treatments. For the finish, an HRA can help
control one of the most pernicious causes of increased costs for both employer
and employee.