Health Reimbursement Arrangements

[Guest jim williams]

Is there a difference between a Health Reimbursement Arrangement and a Self-Insured Medical Reimbursement Plan? Are they one in the same? Both requiring written plan documents?

[sloble@crowleyfleck.com]

My understanding is that an HRA is a kind of self insured medical reimbursement plan. (Health FSAs are another kind). An HRA is employer-funded (no participant contributions), and it is considered a ERISA plan subject to all of those requirments (plan doc, filing, SPD, claims, etc etc)

[GBurns]

Both are section 105 MERPS, the main differences being that the HRA allows the rollover of unused funds to the next year and is employer funded only. There are a few other technical differences and rules, but those are probably the main differences.

Do a Google search using "HSA" and another using "HRA" and you should get a number of good articles from Segal, Miller Chevalier, Groom Law, Sullivan and Cromwell and a number of other top law firms.