HRA expense incurred

[Guest JWR]

I have an HRA plan for insurance premiums. The Employer sends an invoice to the employee for the amount of the annual premium. The employee submits the invoice to the HRA for "reimbursement" even though they have not paid the invoice. A check for the premium is sent to the employee. The employee deposits the check and pays the employer.

Are the rules for self-certification satisfied with this arrangement? Has the expense actually been incurred by the employee without them having any out of pocket expense?

Thanks