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Section 125, Section 105 Administration, COBRA Administration

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Health Reimbursement Arrangements

On June 26, 2002, the U.S. Treasury Department released its revenue ruling allowing Health Reimbursement Arrangements (HRAs), which is likely to be as significant in the evolution of employee benefits as the 1978 laws that enabled Cafeteria Plans and 401(k) plans. Employers may use HRA plans to fund accounts on behalf of employees for items governed by sections 105 and 106 of the tax code, relating to health expenses and insurance premiums.

The essential components of the HRA plan include a funding mechanism through Sections 105 and 106 of the Internal Revenue Code (IRC) where monies are available to the employee for health expenses and insurance premiums. The employer can hold these funds until needed, and the monies can be rolled over year-to-year depending on the parameters of the plan document. Long Term Care premiums are fundable through the HRA, and there are special rules regarding the priority of payment between the Section 125 account and the HRA for any given benefit.


Possible Scenarios

Example 1:

  • Employer purchases a group health plan with a $2500 deductible
  • Through an HRA plan, employer will “buy back” the deductible to $500 for the employee
  • Employee deductible is now $ 500.00
  • Employer exposure is $ 2000.00 times the number of employees taking coverage
  • Employer average payout is about 27% of this exposure
  • Depending on how the plan document is drafted, all or portions of the “savings” can be rolled over to fund benefits for the following year

Example 2:

  • Employer offers an HRA/125 plan combination with a fixed amount available for each employee
  • Choice of health, dental, vision, long term care and other plans are available, together with amounts that can be applied to covered and not covered out of pocket medical expenses
  • The “use it or lose it” rule is eliminated
  • Funds can be rolled over to assist other benefit planning in subsequent years

Under these examples, employers are budgeting the benefit dollars to be available for use by the employees at any time during the plan year.

HRAs will require a separate plan document and are subject to non-discrimination testing under Section 105(h) of the IRC. Depending on the plan provisions of the employer, the plan balance can be transferred with the employee to a new employer’s plan.

To see how much you will save use a Savings Calculator.

For a Benefit Comparison Chart for Health FSAs, HRAs, and HSAs click here.

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