A common question we receive at PeopleKeep is "what are the minimum documentation requirements for HRA claims?" To maintain compliance, an HRA plan must adhere to the IRS rules for valid documentation.
This blog post outlines the HRA claim documentation that a compliant HRA Claims Processing Department requires for approval. To receive tax-free reimbursement from an HRA, the IRS requires an HRA participant to submit documentation showing the following specific items:
Date of Service
Recipient of Service
Services Provided (CPT Codes, description of the service performed)
1. Provider Name Must be Shown on the Documentation for an HRA Claim
The Provider Name is the name of the Clinic, Physician, Dentist, etc. providing the service.
Here is an example of Provider Name:
2. Date of Service Must be Shown on the Documentation for an HRA Claim
The Date of Service is the date that the medical procedure took place. Often times, the payment date or the statement date are submitted in error. In order to verify that the procedure has already taken place and that it is not a duplicate claim, the Date of Service needs to be shown in the documentation.
Here is an example of Date of Service:
3. Recipient of Service Must be Shown on the Documentation for an HRA Claim
Recipient of Service is the name of the person who received the service being claimed. An HRA plan can only reimburse eligible employees and eligible qualified spouses and dependents, so HRA claims processors must verify exactly who received the procedure. If there are multiple persons listed on one invoice, a separate claim must be submitted for each person receiving service.
Here is an example of Recipient of Service.
4. Services Provided Must be Shown on the Documentation for an HRA Claim
Service Provided is the description of the medical procedure that was performed. The IRS has regulations on what medical services can be reimbursed. By requiring that the documentation list the serviced provided, the claims processors can verify that the expense is reimbursable by the HRA. Note: Copay notation alone does not satisfy this requirement.
Here is an example of Service Provided:
5. Amount Must be Shown on the Documentation for an HRA Claim
Amount is the amount of the participant's responsibility and/or payment after insurance is applied. The IRS allows individuals to be reimbursed for the amount of the medical expense that is their responsibility.
Here is an example of Amount:
Items to remember about HRA Documentation:
Documentation must include all 5 IRS requirements, in order to be approved and reimbursed through an HRA.*
If one piece of documentation does not satisfy all requirements, you can submit multiple forms of documentation.
One piece of documentation might require you to submit multiple HRA claims.
*Note: Not every provider receipt contains this information, so be sure to ask the provider for an invoice with these five IRS requirements.