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excepted benefit HRA EBHRA FAQ

EBHRA FAQ: Top questions about Excepted Benefit HRA

The new Excepted Benefit HRA (EBHRA) is a great benefit for employers looking to build a comprehensive benefits package. It offers employees flexibility in how they spend their healthcare dollars. The most frequently asked questions about EBHRA are compiled below. 


The top questions we hear about the new Excepted Benefit HRA, a relative newcomer to HRA benefits.

What is an EBHRA?

An EBHRA stands for Excepted Benefit HRA. It is a tax-advantaged health reimbursement arrangement that pays premiums and qualified medical expenses for excepted benefits like dental and vision coverage. With these types of health reimbursement arrangement HRAs, there's a few things to keep in mind:

  • The EBHRA is offered alongside a group plan.
  • An employee can participate even if they decline participation in the employer’s group health plan.
  • It allows employers to help their employees with health care expenses that aren't covered by insurance within a plan year.

What does EBHRA stand for?

EBHRA stands for Excepted Benefit Health Reimbursement Arrangement. 

HRA Benefits: What are the benefits of offering an EBHRA?

There are some instances in which an employer may wish to offer an HRA in addition to the traditional group health plan, for example to cover the cost of copays, deductibles, or other costs not covered by the plan. Excepted Benefit HRAs allow for higher levels of employer contributions than flexible spending arrangements (FSAs) and the unused funds can rollover year to year. 

What are the requirements for EBHRA?

To keep the HRA limited to excepted benefits, the rules state that EBHRA:

  • Must not be an integral part of the group health plan
  • Benefits must be limited in amount
  • Cannot provide reimbursement for premiums for certain health insurance coverage
  • Be made available under the same terms to all similar situated employees
  • Must submit documents to remain compliant

What are the maximum contribution rates for EBHRA?

The maximum contribution rate for 2020, 2021, and 2022 was $1,800.

For 2023, that maximum contribution rate for EBHRAs rate has gone up to $1,950

In the future, this rate is expected to adjust with inflation but so far the past three years have had the same amount.

What is eligible for reimbursement with an EBHRA?

Here are some of the qualified medical expenses and other eligible expenses that can be reimbursed with EBHRA tax-free.

  • Limited scope dental and vision insurance;
  • COBRA continuation coverage;
  • Short-term limited duration insurance (STDLI);
  • Cost sharing (copays and deductible); and,
  • Long-term care coverage, nursing home care, home healthcare, community-based care, or any combination thereof.

What is not eligible for reimbursement under EBHRA?

HRA funds from the Excepted Benefit HRA may not reimburse premiums that are not considered excepted benefits including:

  • Medicare part A, B, C or D
  • Individual Health insurance coverage
  • Group plan premiums (except COBRA)

Are employees required to enroll in the employer offered group health plan to participate in EBHRA?

No, employees do not have to accept the employer sponsored group health plan in order to participate in EBHRA. This is great news for employees who might not be able to afford the premiums under their group plan, as they will be able to purchase a short-term plan instead and use their EBHRA allowance to reimburse the premium. 

What happens to unused funds at year end?

Employers have the option of designing EBHRA to allow unused HRA funds to carry over year over year. The carryover amounts will not be included when determining if the following year’s limit is exceeded. 

Can employees have both an EBHRA + HSA?

Yes, employees can contribute to an HSA and participate in EBHRA. Employees must ensure their health coverage is compatible with the HSA to participate. 

When can employers start offering EBHRA?

Employers were able to start offering this new type of health reimbursement arrangement HRA, the Excepted Benefit HRA, on January 1, 2020. 

About Take Command  

Take Command is a recognized leader in QSEHRA administration and small business HRA tax strategy. We're also the first and only ICHRA administrator to offer in-house, hands-on employee support. Our team is passionate about HRAs and the impact they can have on businesses of all sizes. 

Ask our experts how to get started today (it's easy!)

This post was originally published in 2019 and has been updated in 2023 to reflected the latest regulatory and policy updates.