youngbenefitslawyer Posted May 3, 2024 Posted May 3, 2024 For HRAs that reimburse employees for premiums, is it acceptable to specify the maximum dollar amount as follows: "the amount of premiums that the employee incurs during the coverage period," or does have to be an actual dollar amount?
Brian Gilmore Posted May 3, 2024 Posted May 3, 2024 I read it as having to be an actual dollar amount-- IRS Notice 2002-45: https://www.irs.gov/pub/irs-drop/n-02-45.pdf An HRA is an arrangement that: (1) is paid for solely by the employer and not provided pursuant to salary reduction election or otherwise under a § 125 cafeteria plan; (2) reimburses the employee for medical care expenses (as defined by § 213(d) of the Internal Revenue Code) incurred by the employee and the employee’s spouse and dependents (as defined in § 152); and (3) provides reimbursements up to a maximum dollar amount for a coverage period and any unused portion of the maximum dollar amount at the end of a coverage period is carried forward to increase the maximum reimbursement amount in subsequent coverage periods. youngbenefitslawyer and acm_acm 2
Mark Mixer Posted May 6, 2024 Posted May 6, 2024 I would echo Brian's response but add that an ER, although required to treat all beneficiaries the same, may be required to "offer" the same amount, but does NOT have to distribute the same amount. Let me give you an example: ER says that all 45 year old get an ICHRA stipend of $700. EE A buys a plan that costs $700 or more and has no money leftover from the ERs HRA contribution. EE B however, buys a $600 plan and $100 now remains ($700 - $600). IF the ER doesn't want to have remaining $'s left in the EEs account for reimbursement of qualified medical expenses, they are not obligated to do and can recapture the remaining funds. Hope that helps and makes sense. This answer is assuming the HRA was an ICHRA. Mark Mixer, Chairman - The HRA Council.
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