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HRA claims incurred by participant prior to death


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Can an HRA pay out a deceased participant's claims for qualified medical expenes that were incurred prior to death? Based on the IRS guidance and other secondary sources I have seen, it looks like you can, and that it is a matter of plan design. I found these comments from the ABA regarding this:

http://www.americanbar.org/content/dam/aba...uthcheckdam.pdf

I've also found HRA SPDs allowing an authorized rep or the estate to submit claims on behalf of the deceased participant.

Any thoughts or insights would be helpful. Thanks!

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