Model HRA Documentation?

[Christine Roberts]

Are there any examples out there yet?

[Ron Snyder]

Certainly there are examples out there. HRAs were being drafted before Notice 2002-45 was issued. I have implemented several. Several of the defined contribution health plan providers such as Definity, Vivius, Lumenos, etc. have their own documents.

Are you really asking whether these vendors have finished their revisions to comply with RR 2002-41 and Notice 2002-45? We are in process of making those revisions and will be done within the next week. I expect that other vendors are in a similar situation.

[Christine Roberts]

Thanks for the update. Are the documents available from these providers (or you) on a self-standing basis, or only if attached to investment or other services?

[Ron Snyder]

Most of the vendors who provide such documents do so in connection with provision of plan administration services for the HRAs (as we do). We work with existing relationships (health carrier, broker, etc.). Since the HRA plan is new, there is no existing relationship to disrupt. Some of my competitors require that the health insurance or health plan TPA services be through them in addition to the HRA administration services.

I would expect that within a short time attorneys and services such as CCH or BNA will be providing documents, but probably not before the end of the year.