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HRA -- Mandatory Employee Contributions?

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I have seen references to HRA funding that recite that a HRA must be: "funded solely through employer contributions or mandatory employee contributions."   

But the vast majority of commentary and even the IRS' own publications say that HRA funding is solely through employer funds.

Are there any instances where one would provide for mandatory employee funding in a HRA Plan? Would the tax treatment of employee funds be the same as employer funds? Are those employee funds at risk? Capable of being withdrawn under certain circumstances?

Any guidance on this category of funding would be appreciated greatly. Thank you!

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I don't know if the same rules apply to HRAs, but I know that 401(k) plans can have mandatory employee (pre-tax) contributions as a condition of employment and those are generally not considered employee salary deferrals, but rather treated as employer contributions. 

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services


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