OPEN ENROLLMENT FOR HRA

There are a few rules that you should be aware of relating to Healthcare Reform (PPACA) and recent changes that allow

reimbursements for individual medical premiums under QSEHRAs and ICHRAs: 

  1. HRA - In general, 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.  

  2. ICHRA - If your HRA reimburses Individually Owned Premiums, where the policy is owned by the individual and is not a group policy, the HRA can reimburse dental, vision, retiree, and specified disease premiums. 

    An HRA can reimburse individual major medical premiums under an Individual Coverage HRA (ICHRA). Employers of all sizes can offer the ICHRA. Group health insurance can also be offered, but not to the same class of employees that are offered the ICHRA. For example, the business can offer full-time employees group health and part-time employees an ICHRA, but they cannot offer full-time employees a choice between group health and the ICHRA. 

For annual discrimination testing and Form 5500 preparation: 

We offer Form 5500 preparation for $200/hr with a $350 minimum.

Discrimination Testing (see 105H Non-Discrim Template.xlsx and complete the first 2 tabs) costs $200/hr (usually 1-2 hours).  

Please contact us if you would like further information.

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 $250 per quarterly report.  Contact BenefitsAssist, inc. for more information.