Jump to content

Pool Funding an HRA


Recommended Posts

We have an employer who wants to pool fund an HRA for select services, i.e., they are putting in $20,000 for their employees to pay for seeing a nurse practitioner on a first-come, first serve basis. If the $20,000 gets used up by June and some employees have not taken advantage of it then they would not receive a reimbursement for seeing a nurse practitioner later in the year. It is available to all employees. Has anyone seen this kind of arrangement before?

I think there would be some nondiscrimination issues if many HCEs used a lot of the benefits early, but I can't determine if this runs afoul of those rules.

Link to comment
Share on other sites

Chaz is correct.

I would question the effectiveness of this program. The idea that someone would visit a nurse practitioner for a well visit strikes me as a win for the NP (income)and a lose for the employee. What would the NP do, a check-up? To what end? The chance of finding something is very slim.

Seems to me that if the employer wanted to provide something of value, this would not be the way to go. Perhaps he should consider another benefit, such as dental, life, DI, etc.

Link to comment
Share on other sites

Without otherwise commenting on the wisdom of the described plan design, the employer and its employee-benefits lawyer should read section 18001 [pages 306-312] of the 21st Century Cures Act.

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

Link to comment
Share on other sites

Without otherwise commenting on the wisdom of the described plan design, the employer and its employee-benefits lawyer should read section 18001 [pages 306-312] of the 21st Century Cures Act.

What am I missing? The act allows for hra if the group meets the following; 1) group is under 50/not subject to ACA, and 2) does not offer health insurance to any of its employees. JRG's 2nd post indicates a group health plan is offered.

Link to comment
Share on other sites

Create an account or sign in to comment

You need to be a member in order to leave a comment

Create an account

Sign up for a new account in our community. It's easy!

Register a new account

Sign in

Already have an account? Sign in here.

Sign In Now
 Share

×
×
  • Create New...