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Small Business Employee Benefits and HR Blog

HRA Plan Document Requirements

February 12, 2012

An HRA is a Health Reimbursement Arrangement that allows tax-free reimbursement of medical and insurance expenses.HRA Plan DocumentsThe HRA Plan Document describes the HRA Plan's terms and conditions related to the operation and administration of the HRA Plan.

HRA Plan Documents must comply with IRS and ERISA rules

Since an HRA is subject to ERISA, a legal HRA plan document must be provided in writing. A Summary of Benefits is not considered an HRA Plan Document or HRA Summary Plan Description (SPD). If an HRA exists without a written HRA Plan Document—it is out of compliance. 

An HRA Plan Document should contain the following: 

    • Name of the HRA Plan Document Administrator
    • Designation of any Named Fiduciaries other than the HRA Plan Administrator under the claims procedure for deciding benefit appeals
    • A description of the HRA benefits provided
    • The standard of review for HRA benefit decisions
    • Eligibility criteria (e.g., classes of employees, waiting period for new hires, and hours worked per week)
    • The effective date of participation (e.g., next day or first of month following satisfaction of the HRA Plan Document eligibility waiting period)
    • Amount the HRA Participant must pay towards the cost of HRA coverage (typically $0)
    • HRA Plan Sponsor's amendment and termination rights and procedures, and what happens to HRA Plan assets, if any, in the event of HRA Plan termination
    • Rules restricting and regulating the use of Protected Health Information (PHI), if Plan Sponsor uses PHI
    • Coordination of Benefits provisions
    • Procedures for allocating and designating administrative duties to an HRA TPA or committee
    • How the HRA plan is funded
    • Information regarding COBRA, HIPAA, and other federal mandates
The small business HRA is 100% compliant.
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