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HRA question


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A question came up on a HRA. I was able to obtain a copy of the Plan document, and the language is, shall we , a bit sparse, and not terribly enlightening. But here goes. 

Plan was established in 2008. In the adoption agreement, under "Maximum Benefits Per Coverage Period" it says: 

"Other: A discretionary amount to be announced by the Employer at the beginning of each Coverage Period." It then goes on to list the maximums for 2008.

So here's the question - the coverage limits have been increased several times since then. Do you think this language would be sufficient, if the amounts are properly communicated to employees each year, or should a Plan amendment have been done each time the limits increased?

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Assuming that the adoption agreement is incorporated as a part of the plan and as long as someone keeps a record of the annual maximum amounts and the amounts are approved subject to the company's regular corporate governance procedures, I don't see a need to revisit this provision.

If the plan has not been revised since 2008 and is "a bit sparse, and not terribly enlightening," however, perhaps a review by counsel might be in order.

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