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New regulations have been released expanding the ways in which HRAs can be used to provide health benefits to employees.

Understanding the different HRA options

Health coverage is a focus for many employers as they look for innovative and cost-effective ways to provide benefits. New regulations have been released expanding the ways in which HRAs can be used to provide health benefits to employees. Traditionally, HRAs have always been required to integrate with a group health plan. However, regulators now allow for several options for employer-funded, tax deductible plans that may provide pre-tax aid to employees towards their costs for healthcare.

Individual Coverage HRAs (ICHRA)

Employers of any size can establish an HRA that reimburses the employee’s premiums for major medical insurance purchased in the individual market, as well as other Code §213(d) medical expenses. ICHRAs are not subject to statutory limits on the benefit amount that can be provided.

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Qualified Small Employer HRA (QSEHRA)

While similar to ICHRAs, QSEHRAs are available only to small employers that are not subject to healthcare reform’s employer shared responsibility provisions — i.e., employers that do not have 50 or more full-time employees, including full-time-equivalent employees, during the preceding year.

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Excepted Benefit HRA (EBHRA)

The Excepted Benefit HRA can be offered in addition to a traditional group health insurance plan and permits employers to finance pre-tax dollars for additional medical care (such as copays, deductibles, premiums for vision, dental, COBRA and short-term insurance coverage), even for employees who have declined enrollment in a traditional group health insurance plan.

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Understanding the Different HRA Types

We’ve provided a helpful chart that illustrates some of the key differences between the various HRAs that are available, including the two additional HRA types that are available for plan years beginning on or after January 1, 2020.

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QSEHRAICHRAEBHRA
Group Health Plan RequirementsCan’t be offered with a group health policyCan be offered with a group health policy, but employees cannot have a choice between the group policy and the HRAMust be eligible for group health benefits
Eligible ExpensesIndividual coverage premiums and out-of-pocket medical expenses (pre-tax group health plan premiums are reimbursed after-tax)Individual coverage premiums, Medicare-related premiums, and out-of-pocket medical expenses (no group health plan premiums)Out-of-pocket medical expenses; premiums for COBRA, excepted benefit coverage, or STLDI
Employee Size RestrictionsLimited to businesses with fewer than 50 FTE employeeNoneNone
Maximum Reimbursement LimitsFor 2024, the maximum reimbursement for single covered is limited to $6,150 and $12,450 for those with employee + dependent coverageNoneFor 2024, $2,100, regardless of ones coverage tier

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OCA’s Specialty HRA options can help deliver the experience and business results you’re looking for.

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