HSA and HRA simultaneously

[Belgarath]

A colleague has been receiving different responses to the following. I don't pretend to know! Any thoughts? Thanks.

Is it permissible to offer both an HSA and HRA to employees participating in an HSA eligible group health insurance plan?

 

For example; is it okay to have an HSA cover the first $1,300/$2,600 in deductible expenses and then have an HRA pick up some or all of the remaining deductible and/or co-insurance expenses?

 

Are there other options, say where the HRA pays the first $X in deductible expenses and the HSA could pick-up expenses after the HRA benefits have maxed out.

[Joe Priselac]

The answer to your first two questions is yes, it is permissible. The last paragraph would describe an impermissible plan design. The HRA can not pay before the annual deductible has been satisfied unless it is reimbursing certain excepted benefits like dental.

[spiritrider]

Technically, I do not think it would be an impermissible plan design to have a general purpose HRA and an HSA. It would just be dumb and render the participant ineligible for HSA contributions.

See Rev. Rul. 2004-45

The most common HRAs complimenting an HSA are limited purpose and/or post-deductible not unlike similar FSAs.

[Belgarath]

Thank you both.