Church's HRA, 5 Employees, HIPAA Exception?

[Guest LCarr]

Please help with an answer to whether or not this scenario qualifies us for the HIPAA exception.

Small church, 9 employees on payroll.

Five employees participate in the insurance plan (four families, 2 employees from same family) with Kaiser

Counting all family members covered in the plan, total is 15

Church leadership would like to set up an HRA to fund it in-house (self-administered) when the plan renews in May 2012

Our bank would issue the debit cards (we'll craft a card agreement for each employee to sign and the cards will have a limit). New account would be set up to hold the funds for all cards.

Our in-house HRA will reimburse via the debit cards the 11 cardholders [employees+spouses+young-adult-covered plan members] for out-of-pocket expenses, which according to the Kaiser plan we selected will only be prescriptions and co-pays

Does this scenario meet the qualifications for the "self-funded" AND "less than 50 employees" HIPAA exception?

If it does not, we will use a third-party administrator. But that is not what the church wants to do as of now UNLESS it will obligate us to comply with HIPAA security and privacy regulations, which would clearly overwhelm the in-house plan administrator = ME.

Thank you!

[Clarifying Health]

Please help with an answer to whether or not this scenario qualifies us for the HIPAA exception.

Small church, 9 employees on payroll.

Five employees participate in the insurance plan (four families, 2 employees from same family) with Kaiser

Counting all family members covered in the plan, total is 15

Church leadership would like to set up an HRA to fund it in-house (self-administered) when the plan renews in May 2012

Our bank would issue the debit cards (we'll craft a card agreement for each employee to sign and the cards will have a limit). New account would be set up to hold the funds for all cards.

Our in-house HRA will reimburse via the debit cards the 11 cardholders [employees+spouses+young-adult-covered plan members] for out-of-pocket expenses, which according to the Kaiser plan we selected will only be prescriptions and co-pays

Does this scenario meet the qualifications for the "self-funded" AND "less than 50 employees" HIPAA exception?

If it does not, we will use a third-party administrator. But that is not what the church wants to do as of now UNLESS it will obligate us to comply with HIPAA security and privacy regulations, which would clearly overwhelm the in-house plan administrator = ME.

Thank you!

Hi Lcarr,

What did you end up deciding for administering your HRA?

If you're still debating this, or for others who are, here are two useful articles:

15 Features to Expect from an HRA Administrator

3 Reasons an Employer Should use an HRA Administrator

Happy to answer any questions you might have about HRAs or HRA Administration!