05/25/2017

What are the reporting requirements for Health Reimbursement Arrangements?

Group health plans have several reporting requirements. Since Health Reimbursement Arrangements (HRAs) are considered group health plans, many of the requirements that apply to group health insurance plans also apply to HRAs.

Medicare Secondary Payer Reporting

In an attempt to reduce unneeded payments, Medicare requires group health plans, including HRAs, to pass participant eligibility and coverage information to Medicare.  This is commonly referred to as the Medicare Secondary Payer provisions or MSP Rules.  The information is required to be submitted by the third party administrator or insurer administering the plan.  If the plan is self-insured and self-administered by the employer, the employer is required to report the information to Medicare.

Patient-Centered Outcomes Research Institute Fees (PCOR)

As part of healthcare reform, group health plans are required to pay an annual fee to help fund The Patient-Centered Outcomes Research Institute. Since HRAs are considered group health plans, the fee applies to these plans.  The fee is applicable for plans beginning on October 1, 2012 through October 1, 2019.  HRAs that are integrated with a self-insured group health insurance plan only pay the fee once for those covered under both plans. HRAs integrated with a fully-insured group health insurance plan must pay the fee for each plan separately. The amount of the fee is reviewed annually and updated as needed based on healthcare inflation.  For more information on PCOR fees click here.

Form 5500 Reporting

HRAs with 100 or more participants are required to file a Form 5500.   The Form 5500 is filed electronically and the signor is required to have an electronic signature established to finalize the form.

These are just a few examples of the reporting requirements for HRAs. While not every item applies to every HRA, it is important to be aware of rules in case there are changes in plan design or plan participation rates that could result in the HRA being subject to different requirements.

BusinessPlans, Inc. – myCafeteriaPlan does not intend to provide legal or tax advice and information contained in this article should not be interpreted as such. Regulations governing pretax plans are often open to interpretation and should be reviewed with your legal or tax advisor before making any decisions regarding your plan.

Posted 5/25/17