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Starting a
Healthcare Reimbursement Account
Recently the
IRS has cleared the way to allow employers to pay cash benefits
for health care that carry balances over from year to year.
These plans are called Healthcare Reimbursement Accounts (HRA).
HRA plans offer significant advantages over earlier health plan
designs including plans known as "Medical Reimbursement Plans",
"Premium Only Plans", "Cafeteria Plans" and "Medical Savings
Accounts". In oversimplified terms, the HRA allows an employer
to take the position "if the money is used for health-related
purposes, then it is not taxed as wages, regardless of other
details".
Employers
and their benefits advisers are still experimenting with HRA
designs that allow for the most flexibility at minimal cost. One
of the biggest issues in starting a HRA plan is the decision of
whether to use a "funded" or "unfunded" plan. In contrast to
what the HRA name implies, most HRAs are not using an "account"
setup in the way that we think of a 401(k)accounts or Medical
Savings Accounts. HRAs without an account to hold contributions
are known as "unfunded" plans. These are easier to setup and
administer but can trigger a long-term financial liability for
the employer that must be handled responsibly. Here are a few
other issues that employers should consider when starting a HRA
plan.
HRA Technical Brochure
HRA Points

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HRAs have nothing to do with health
insurance. They can be used with or without
insurance. The employer's decisions about
health insurance should have no impact on
the decision to use a HRA. |
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The employee may elect to use HRA to pay for
health insurance. There is no requirement
that employees have the same type of health
insurance. |
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If the employer starts a HRA plan, it
usually makes sense to fund all employee
health benefits through the HRA plan. It
normally would not makes sense, for example,
for an employer to have an employee benefit
that provides for the employer to pay for
health insurance and then, separately, a
benefit that funds a HRA. For simplicity of
operation and easier compliance with
IRS
participation rules, the two should probably
be combined. |
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An HRA requires a written document. There is
no specific format required, but it makes
sense to use a "tried and true" traditional
benefit plan format utilized by benefit plan
consultants. These documents are available
at minimal cost. |
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There is no requirement that an employer
actually set up a separate account or trust
to hold money from plan contributions. In
some cases this might be desired. If an
account is used, it may use individual
accounts for each employee or be a single
"pooled account " for all employees. |
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Small business HRAs may not require the
filing of an annual tax return. If a plan
can be designed to avoid an annual tax
return, the employer will probably save $100
to $200 in annual tax return preparation
fees. |
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If the HRA does require an annual tax
return, this is not a "do-it-yourself"
project. In the event that there is an IRS
issue in the future (this happens in about
1/2 of all employee benefit plans) the
ability to show fair business intent through
the use of independent accountant or adviser
is more likely to help avoid an appearance
of tax evasion. Since employee benefit plan
rules change every year, it is smarter to
spend the small amount to have an employee
benefit specialist prepare the HRAs Form 550
report to the
IRS. |
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It is not difficult to justify the cost of
starting a HRA plan. The average cost of
setting up and running a small business HRA
is about $500 per year. Each $1000 paid
through a HRA will cost about $400 in wage
taxes. (Remember that HRA contributions are
not subject to federal or state income tax,
social security tax or FUTA, unemployment
wage tax or worker's compensation premiums),
So the "breakeven" point for the plan is
only about $1200 in total contributions for
the year. |
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One "hidden" but significant benefit of an
HRA plan is that it allows
employees
to take advantage of less expensive
individual health insurance plans
that are not available through
other employer-sponsored plans. Of course,
the employee receives the same tax-free
status as with group insurance plans. The
employer should be aware that some states
have insurance laws designed to make it
difficult to exploit this loophole, and the
employer should be careful to comply.
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Like many other employee benefit plans, the
best results will be obtained if the HRA is
custom-designed for the individual business
rather than use a "one-size-fits-all"
approach. But this means working with a
benefits adviser who takes the time to learn
the needs of your business and builds the
best-suited features into the new HRA plan. |
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