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What Is a Section 105 Health Reimbursement Arrangement? (HRA)

If you're running a small business, navigating healthcare benefits can seem like a daunting task. Enter Section 105 Health Reimbursement Arrangements (HRAs) — your flexible ally in the complex world of health benefits. This guide is here to demystify Section 105 HRAs for you, highlighting their adaptability and how they can be a perfect fit for your business's unique needs. By understanding what Section 105 HRAs are, their benefits, and the different plans available, you can offer a health benefits package that not only supports your employees but also aligns with your financial realities.

How Section 105 Health Reimbursement Arrangements Work for Small Businesses

Let's explore how Section 105 HRAs can be a game-changer for your small business's health benefits strategy.

Introduction to Section 105 HRAs

Section 105 Health Reimbursement Arrangements (HRAs) present a strategic solution for small business owners aiming to provide health benefits to their employees. These plans are employer-funded plans that reimburse employees for medical expenses and premiums, under guidelines that offer significant tax advantages. They have the capacity to reduce taxable income for businesses while providing tax-free health benefits to employees, fostering a mutually beneficial financial scenario. 

HRAs provide unparalleled flexibility and control; business owners can tailor these plans extensively to fit their budget constraints and employees' needs, choosing what expenses are covered and setting limits on reimbursements. This adaptable approach empowers small businesses to manage their healthcare spending efficiently, ensuring they can offer competitive benefits in a cost-effective manner.

Definition and Background of Section 105

A Section 105 HRA is an employer-funded plan that reimburses employees for medical expenses, including insurance premiums, up to a certain amount. This framework is not just about providing health benefits; it's about doing so in a way that's tax-advantaged for both you and your employees.

Why Section 105? The name comes from Section 105 of the Internal Revenue Code, which specifies the guidelines for these reimbursement plans. Historically, HRAs have been a part of the benefits landscape for decades, but recent regulations have made them increasingly accessible and flexible for small businesses. This shift means you now have more control over your healthcare spending, tailoring the plan to fit your budget and your employees' needs.

Benefits of Implementing a Section 105 HRA

  • Tax Efficiency: Contributions made to the HRA are tax-deductible for your business, and reimbursements received by employees are generally tax-free.
  • Customizability: You decide how much to contribute, within legal limits, allowing you to control costs while offering valuable benefits.
  • Employee Satisfaction: Employees get the freedom to choose their healthcare services and providers, increasing satisfaction with their benefits package.

Want to see how an HRA could benefit your business and your bottom line?

Types of Section 105 plans

  1. Standard HRA (Health Reimbursement Arrangement):This is the traditional form of HRA, where employers reimburse employees for qualified medical expenses up to a certain limit. It's a flexible plan that can be offered to employees regardless of whether they have health insurance.
  2. Integrated HRA: Designed to work alongside a group health insurance plan, this type of HRA allows employers to reimburse employees for out-of-pocket medical expenses not covered by the group plan, including deductibles and co-payments.
  3. Excepted Benefit HRA (EBHRA): EBHRAs allow employers who offer traditional group health plans to provide additional funds for certain excepted benefits, such as dental and vision care, without needing to be integrated with the group plan.
  4. Qualified Small Employer HRA (QSEHRA): Specifically for businesses with fewer than 50 employees that do not offer group health insurance, QSEHRAs can reimburse employees for individual health insurance premiums and medical expenses, within certain contribution limits set by the IRS.
  5. Individual Coverage HRA (ICHRA): ICHRAs reimburse employees for individual health insurance premiums and other medical expenses. Unlike QSEHRAs, ICHRAs can be offered by employers of any size and can be customized to different classes of employees, providing a great deal of flexibility in how benefits are structured.

Eligibility and Requirements

Understanding who can offer a Section 105 Health Reimbursement Arrangement (HRA) and the associated regulations is key to ensuring your small business not only provides valuable benefits but does so in compliance with current laws. 


Who Can Offer a Section 105 HRA

Virtually any employer can set up a Section 105 HRA, with the primary condition being that you operate as a legitimate business. Whether you're a sole proprietor, a partnership, or a corporation, you have the potential to leverage this tool. However, the specifics of who can benefit from the plan—like whether business owners and their families can participate—vary depending on your business structure and the type of HRA.

For small businesses, particularly those with fewer than 50 employees, Section 105 HRAs offer a flexible option to provide health benefits without the need for traditional group health insurance. This makes it an attractive choice for small enterprises seeking to enhance their benefits offerings while controlling costs.


Regulations and Compliance for Section 105 HRAs

Compliance with Section 105 HRA regulations requires careful attention to detail.

Here are key areas to focus on:

  • Plan Documentation: The IRS requires detailed documentation of your HRA plan, including the plan's coverage, eligibility, and reimbursement rules. This documentation must be readily available to all eligible employees.
  • Non-Discrimination: Your HRA must comply with nondiscrimination rules, ensuring it benefits all eligible employees fairly. This means you cannot offer substantially better benefits to highly compensated employees over others.
  • Affordable Care Act (ACA) Compliance: For HRAs to be ACA-compliant, they must meet specific standards, including offering preventive care and covering essential health benefits. Understanding how your HRA fits into the ACA landscape is crucial to avoid penalties.
  • Annual Notice Requirements: Employers are required to provide employees with an annual notice explaining the HRA, including the available benefit and terms of use. This notice must be given a certain number of days before the beginning of each plan year.

Staying on top of these regulations and compliance requirements is essential for successfully implementing and maintaining a Section 105 HRA. When you partner with a reputable HRA administration platform, like Take Command, you can simplify compliance, allowing you to focus on running your business.

Setting Up a Section 105 HRA

Embarking on the journey to set up a Section 105 Health Reimbursement Arrangement (HRA) for your small business is a commendable step towards offering your employees meaningful health benefits. The process involves careful planning and adherence to regulations, but the rewards in terms of flexibility, tax advantages, and employee satisfaction are well worth the effort. Let's walk through the steps for implementation and the critical aspects of documentation and plan design.

Steps for Implementation

  1. Assess Your Business's Needs: Start by evaluating your business's health benefits objectives and budget. Consider how a Section 105 HRA can meet these needs and which employees you aim to cover.
  2. Choose an HRA Type: There are different types of HRAs to consider, including standalone HRAs and those integrated with traditional health plans. Your choice will depend on your business size, needs, and the level of benefits you wish to provide.
  3. Partner with a Benefits Advisor or HRA Provider: Navigating the complexities of setting up an HRA can be challenging. Partnering with a knowledgeable benefits advisor or a reputable HRA administration platform can streamline the process, ensuring compliance and an optimal plan design.
  4. Design Your Plan: Decide on the details of your HRA, including reimbursement limits, eligible expenses, and eligibility criteria for your employees. This step is crucial in tailoring the HRA to your business's specific needs.
  5. Draft and Finalize Plan Documents: Create the plan documentation that outlines the specifics of your HRA, ensuring it complies with IRS requirements and healthcare regulations.
  6. Communicate with Your Employees: Before implementing the HRA, communicate the new benefits to your employees. Explain how the HRA works, its benefits, and how they can use it for their healthcare expenses.
  7. Implement and Monitor the Plan: With everything in place, launch your HRA. It's important to monitor the plan's performance and employee utilization to make any necessary adjustments in the future.

Documentation and Plan Design

Comprehensive and clear documentation is essential for a successful Section 105 HRA, outlining operations, eligibility, expenses, and employee guidelines to ensure compliance and serve as a helpful resource. Embrace flexibility in your plan design to meet your workforce's needs, choosing benefits and coverage that reflect your company's values. Implementing a Section 105 HRA, from understanding business needs to educating employees, offers valuable health benefits that promote employee well-being and contribute to business success.

Managing and Maintaining a Section 105 HRA

Once a Section 105 HRA is established, ongoing management and maintenance are vital for smooth operation and compliance. Essential tasks include meticulous record-keeping, reporting, and following administrative best practices to optimize benefits and ensure regulatory adherence.

Record-Keeping and Reporting

Accurate record-keeping is the backbone of a successful Section 105 HRA. Here's what you need to focus on:

  • Documentation of Expenses: Keep detailed records of all healthcare expenses reimbursed through the HRA. This includes dates of service, descriptions of the services provided, and proof of payment. These records are essential for tax purposes and for verifying the legitimacy of claims.
  • Employee Reimbursements: Track all reimbursements to employees meticulously. This not only helps in managing your budget but also ensures that you can report these payments accurately on your business taxes.
  • Compliance Documentation: Maintain all documents related to the HRA's compliance with IRS regulations and the Affordable Care Act. This includes plan documents, notices given to employees, and any correspondence regarding the plan.

Best Practices for Administration

To streamline the administration of your Section 105 HRA and enhance its effectiveness, consider the following best practices:

  • Use a Third-Party Administrator (TPA): Partnering with a TPA (like Take Command) can alleviate the burden of managing the HRA. TPAs have the expertise to handle claim processing, compliance issues, and day-to-day administration tasks efficiently. 
  • Communicate Clearly with Employees: Regular communication about how the HRA works and its benefits can increase employee satisfaction and utilization of the plan. Consider holding informational sessions or creating easily accessible online resources for employees.
  • Regular Review and Adjustment: The needs of your business and your employees can change over time. Annually review the HRA's performance, costs, and feedback from employees to determine if adjustments are needed. This might involve changing the reimbursement limits or expanding the list of eligible expenses.
  • Alternatives to Section 105 HRAs

While Section 105 Health Reimbursement Arrangements (HRAs) offer considerable benefits, they're not the only option available for small businesses looking to provide health benefits to their employees. Qualified Small Employer Health Reimbursement Arrangements (QSEHRAs) and Individual Coverage HRAs (ICHRAs) are two alternatives that have gained popularity. Understanding the differences and similarities between these options can help you decide which is the best fit for your business's specific needs.

Comparison with QSEHRAs and ICHRAs

QSEHRAs: Designed specifically for small employers with fewer than 50 full-time employees who do not offer group health insurance. QSEHRAs allow employers to reimburse employees for health insurance premiums and medical expenses, up to a set annual limit. The key advantage of QSEHRAs is their simplicity and suitability for very small businesses, but they come with caps on reimbursement amounts.

ICHRAs: A more flexible option that can be offered by employers of any size and can be integrated with individual health insurance coverage. Unlike QSEHRAs, ICHRAs do not have a cap on employer contributions, allowing for greater flexibility in designing the benefit. 

Choosing the Right HRA for Your Business

Selecting the most suitable HRA involves evaluating your business's unique circumstances and goals.

Here are some considerations to guide your decision:

  • Business Size and Structure: If your business has fewer than 50 employees and does not offer group health insurance, a QSEHRA might be the simplest and most cost-effective option. Larger businesses, or those looking for more flexibility, might prefer the ICHRA.
  • Benefits Budget: Consider how much you're willing to allocate towards employee health benefits. QSEHRAs have annual contribution limits, while ICHRAs allow for more generous and flexible funding.
  • Employee Needs: Assess the healthcare needs and preferences of your workforce. If offering a customizable and flexible benefits package is a priority, ICHRAs might be more appealing.

Conclusion: Is a Section 105 HRA Right for Your Small Business?

Deciding whether a Section 105 Health Reimbursement Arrangement (HRA) is the right choice for your small business involves weighing several key considerations.

Summary of Key Considerations

  • Tax Advantages: Section 105 HRAs offer significant tax benefits for both employers and employees, making them a cost-effective solution for health benefits.
  • Flexibility and Control: These plans provide the flexibility to define contribution limits and covered expenses, allowing you to tailor the benefits to your business's budget and your employees' needs.
  • Regulatory Compliance: While offering great benefits, HRAs require adherence to specific regulations and documentation. Ensuring compliance is essential for reaping the full advantages of an HRA.

Next Steps and Resources

If you're leaning towards implementing a Section 105 HRA, your next steps should involve:

  1. Consulting with a Benefits Advisor: A knowledgeable advisor can help you navigate the complexities of HRAs, ensuring that your plan is compliant and tailored to your needs.
  2. Researching Providers: Look for reputable HRA administration platforms that can simplify the setup and management of your plan.
  3. Educating Your Employees: Once you decide on an HRA, communicating its benefits and how it works to your employees is crucial for maximizing its value.

Ready to get started with an HRA? Talk to the experts at Take Command about the best option for you. 


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