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.
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 HRA’s 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?
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
What are the maximum contribution rates?
The maximum contribution rate for 2020 is $1,800. This rate is expected to adjust with inflation.
What is eligible for reimbursement?
- 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?
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 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 can start offering Excepted Benefit HRAs on January 1, 2020.
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