Life and Health Insurance · Accident and Health Insurance · 6 min read
Employer Reimbursement and Spending Accounts
- Distinguish between the funding structures, ownership, and tax treatments of Health Reimbursement Arrangements (HRAs) and Flexible Spending Accounts (FSAs).
- Explain the operational mechanics of medical FSAs, including the uniform coverage rule, use-it-or-lose-it guidelines, and eligible expenses.
- Identify how HRAs and FSAs interact with Health Savings Accounts (HSAs) and continuation coverage rules such as COBRA.
Health Reimbursement Arrangements (HRAs)
A Health Reimbursement Arrangement is an employer-funded plan that reimburses employees for qualified medical expenses. Health Reimbursement Arrangements are funded solely by employer contributions. Employees are not permitted to contribute to a Health Reimbursement Arrangement through salary reductions. While FSAs rely heavily on employee salary deductions, HRAs strictly prohibit employee contributions.
The employer sets the annual HRA allowance, subject to any federal limit that applies to the type of HRA. Employer contributions to a Health Reimbursement Arrangement are generally excludable from an employee's gross income, and reimbursements received by an employee for qualified medical expenses are tax-free. Employers generally deduct HRA reimbursements as business expenses; they do not deduct the same amount twice as both a contribution and a reimbursement.
An HRA can reimburse medical care expenses defined under Internal Revenue Code Section 213(d). Depending on plan design, an HRA may be permitted to reimburse individual health insurance premiums. Some HRAs can be paired with a high-deductible health plan or other employer group health coverage; if you want to contribute to an HSA, the HRA must also meet HSA eligibility rules.
An HRA is an employer-sponsored reimbursement arrangement, not an employee-owned savings account. Because an HRA is owned by the employer, account balances are not automatically portable when an employee leaves the company. Employers may choose whether unused HRA funds roll over to the following plan year. An employer may design an HRA so unused balances are forfeited when employment ends, subject to applicable continuation coverage requirements. Unlike an FSA, an HRA does not require the uniform coverage rule unless the employer voluntarily adopts that provision in the plan document.
Common mistakes
- Thinking that employees can make pretax salary reduction contributions to an HRA; HRAs are funded solely by employer contributions.
- Believing that an employer can offer both a 2.5-month grace period and a limited carryover provision for the same medical FSA in the same plan year; a plan can offer one or the other, but not both.
- Assuming an employer can garnish a departing employee's final paycheck to recover FSA reimbursements that exceeded their payroll deductions under the uniform coverage rule.
- Assuming that HRAs and FSAs are portable, employee-owned accounts like HSAs; both HRAs and FSAs are employer-sponsored arrangements and do not automatically follow the employee.
Key points
- Health Reimbursement Arrangements (HRAs) are funded solely by the employer and strictly prohibit employee contributions.
- Medical Flexible Spending Accounts (FSAs) are offered through Section 125 cafeteria plans and funded primarily by employee pretax salary reductions, which are exempt from federal income, Social Security, and Medicare taxes.
- You cannot participate in a cafeteria plan medical FSA through your own self-employment, partnership, or S corporation if you own more than two percent of that corporation, but you may qualify through a separate employer.
- The uniform coverage rule requires the full annual medical FSA election to be available on day one of coverage, and employers cannot accelerate deductions to recover funds if an employee leaves midyear.
- Medical FSAs follow a use-it-or-lose-it rule, though employers may offer either a grace period of up to two and a half months or a limited dollar carryover, but never both in the same plan year.
- Qualified medical expenses reimbursed by an FSA or HRA cannot be claimed as an itemized deduction on personal tax returns, and medical FSAs cannot pay for health insurance premiums or purely aesthetic cosmetic surgery.
- General-purpose medical FSAs disqualify individuals from contributing to an HSA, whereas limited-purpose FSAs covering dental, vision, or preventive care remain HSA-compatible.
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