HRA reimbursement - different levels depending upon Health ins. status?

[Belgarath]

Can an HRA base the reimbursement levels upon health insurance status? By that I mean, can it be $1,000 if you are enrolled in the health insurance as a single, $2,000 if as a 2-person, and, say, $3,000 if you have family coverage?

[leevena]

Yes

[Belgarath]

Thanks. Now, suppose the only people enrolled in family coverage are HCE's - would this run afoul of 105(h) automatically, or is it just subject to normal testing? (I'm assuming the latter) - thanks again.

[leevena]

Need to do non-discrimination testing.  Normal rules apply.

[Belgarath]

As an additional item in this area - an employer is considering doing something to provide higher benefits to lower income individuals. For example, say they have an HDHP with a $5,000 deductible, and maximum OOP of, say, $10,000. They are considering an HRA that would provide that no one would pay more than (x)% of income, and the HRA would pay all the rest. So if you make $20,000, your maximum that you'd have to pay would only be 1/2 of the maximum that would have to be paid by someone making $40,000.

Seems like a nondiscriminatory way of doing things. Do you see any problems with it? I wasn't sure if, for example, another member of the household (such as spouse) was getting health insurance through a health exchange, if this would cause any problems?

[leevena]

From an arms length, it looks ok.  Cannot comment on other member of household, I do group only, not individual.  

[Belgarath]

Thanks.