Open Enrollment for HRA
There are a few rules that you should be aware of relating to Healthcare Reform (PPACA):
HRA - In order to keep offering an HRA, employers must also offer a separate major medical group plan and the HRA enrollment can only be for employees who also enroll in the separate major medical group plan.
This restriction applies to employers of all sizes unless you qualify for a Qualified Small Employer HRA (QSEHRA) which means employer must not be categorized as an Applicable Large Employer (Section 4980H(c)(2) - Cannot have 50 or more FTE and cannot offer group health benefits to any employee.
HRA - If your HRA reimburses Individually Owned Premiums, where the policy is owned by the individual and is not a group policy, the HRA can only reimburse dental, vision, retiree, and specified disease premiums. An HRA can no longer reimburse individual major medical premiums as pre-tax. This does not affect pre-taxing of GROUP major medical premiums under Section 125 (POP plans).
For annual discrimination testing and Form 5500 preparation:
Medicare reporting for HRAs:
As of January 1, 2012 plan years, Employers must report to Centers for Medicare & Medicaid Services (CMS) any employee, spouse, or dependent who is covered by both Medicare and the HRA if the HRA amount is $5,000 or more (including rollovers). BenefitsAssist, inc. can assist the Employer in sending the report to CMS. The current charge is $150 per quarterly report. Contact BenefitsAssist, inc. for more information.