Integrated HRA

[Guest PEMAQUID95]

My TPA is telling me that the spouse of an employee, who is also an employee, cannot participate in our company sponsored HRA. Our company offers a HRA to employees who "opt out" of health coverage and provide proof of alternative coverage (non-market place). Two employees, husband and wife, work for same company. Husband elects family coverage, wife opts-out and is enrolled in HRA. My understanding is that each employee has an individual right to make an election, what am I missing? Furthermore, there seems to be a disconnect as to whether or not our HRA is considered integrated. Who sponsors the group coverage is not a factor, simply that the employee enrolled in the HRA is actually enrolled in other group coverage. What am I missing here?

[Flyboyjohn]

I think under the latest rules the HRA has to be integrated with the employer's group health plan and "other" health insurance doesn't qualify

[lvena]

As usual, I am a little confused by your question, so please bear with me as I answer.

An integrated HRA must benefit only employees wo are covered by the primary group plan offered by the employer. So even if someone is eligible for covereage, but they have declined to enroll, they cannot participate in the HRA. Is it possible the tpa is denying the spouse access to the HRA because the spouse is covered under the group plan as the other employees dependent?

[Guest PEMAQUID95]

The TPA hasn't been able to adequately explain their position, they only cite the regulation which is frustrating because the regulation seems to say the employee spouse can participate. I can't find anything that speaks to this scenario so I am left to interpretation. The first sentence of your 2nd paragraph says that "An integrated HRA must only employees who are covered by the primary group plan offered by the employer." The employee is covered by the primary plan, through her spouse...??

[lvena]

Bear with me, since I do not have the plan documents available to review. But you state that the HRA is available to employees who; 1) Opt out of your sponsored plan, and 2) provide proof of alternative coverage. Assuming that the plan documents are well written, then this employees appears to have failed the test. She may have opted out of your plan as an employee, but did not satisfy the second (having alternative coverage) because her coverage is still your plan.

Suggest reading of the plan documents.

[Guest PEMAQUID95]

I read notice 2013-54 and under one of the Q&A's (#4) the criteria (among many) for satisfying the integration method states that the HRA is available to employees who are enrolled in non-HRA coverage ("for example, the HRA may be offered only to employees who do not enroll in the employer's group health plan but are enrolled in other non-HRA group coverage, such as a plan maintained by the employer of the employee's spouse"). The employee did not elect her employer's health plan, but is enrolled in it through her spouse. How can the employee NOT have an independent election right?