Important deadlines for health reimbursement arrangements

By Elizabeth Walker on March 27, 2026 at 12:45 PM

If you’re an employer who recently implemented a health reimbursement arrangement (HRA), you may have questions about required deadlines for reimbursing employees’ medical expenses, submitting tax forms, and fulfilling IRS and ERISA requirements. Your eligible employees may also want to know how long they have to submit their healthcare costs for approval.

As a rule of thumb, the HRA plan documents you draft when setting up the benefit define your reimbursement deadlines. Similarly, the IRS and ERISA set compliance regulations and tax form filing deadlines that you must follow to avoid penalties.

The article below will highlight a few of the most important reimbursement, expense submission, and compliance deadlines you’ll need to know to manage an effective HRA.

In this blog post, you’ll learn:

The key deadlines for submitting and reimbursing HRA expenses, including timelines for employees and employers.
How compliance requirements impact HRA administration.
Important employee notice requirements and penalties to avoid when managing an HRA.

Expense submission and reimbursement deadlines

Some major HRA deadlines impact when your employees must submit their medical expenses and when you must reimburse them. Let’s go over a few of those situations below.

Reimbursement deadlines for employers

Regardless of the type of HRA, you must have formal plan documents to comply with federal and ERISA guidelines and to receive tax advantages. These plan documents outline HRA timing rules, including the deadline for employers to reimburse employees for out-of-pocket medical expenses they’ve submitted for reimbursement.

Organizations usually must reimburse healthcare costs within 90 days of approval during the normal life of the plan, also known as the benefit year. The benefit year is the specific length of time an organization sets its plan to run for. Employers should list the benefit year's date range in their plan documents, along with the HRA’s effective date.

A typical benefit year spans 12 months but can be shorter or longer depending on how you set up your HRA. For example, you may set your first benefit year to run from August through December, and subsequent years to run from January through December.

The absolute final day that an employer with a standard 90-day runout period can reimburse an employee for qualifying expenses is 90 days after the end of the plan year.

Expense submission deadlines for eligible employees

Eligible employees typically can submit expenses for reimbursement at any time during the benefit year. For example, if the benefit year begins in January and ends in December, active employees can submit expenses through the end of December, regardless of when they incurred them during that time period.

It’s a good habit for employees to submit proof of purchase for healthcare items and monthly premiums shortly after they incur them. The IRS requires employees to submit claim documentation or proof of their expenses (such as an invoice, an explanation of benefits, or a receipt) along with their reimbursement request.

Usually, current employees only need to submit proof of health insurance coverage and their premium costs once at the beginning of the plan year to receive monthly reimbursements. However, they may need to attest regularly that they still have qualifying coverage.

The longer an individual employee waits to make a claim submission for their expense, the more likely they are to lose track of their receipt or written proof. Without proper proof, they won’t be able to receive reimbursements for their purchases.

With PeopleKeep, unused amounts expire at the end of the benefit year, so employees lose their benefit if they miss the deadline. However, employees can still submit previously incurred expenses from during the plan if there’s an applicable run-out period. Make sure you communicate with your staff early and often as deadlines for submitting medical expenses approach. That way, your current employees don’t miss out on using their HRA funds.

Expense submission deadlines for newly ineligible employees

In some cases, organizations must reimburse expenses after an employee becomes ineligible for benefits.

An employee may lose plan eligibility for several reasons, including:

Leaving the organization voluntarily
Being terminated by their employer
Having a change in individual health insurance status

Whatever the reason, employees have 90 days after they lose eligibility to submit medical expenses for reimbursement. However, to receive reimbursement for the expense, the employee must have incurred it while still eligible for the HRA.

Reimbursement deadlines for after the plan year ends

Finally, there are deadlines for when employers can submit reimbursements to employees after the plan year ends. As with losing eligibility, employees have up to 90 days after a benefit year ends to submit medical expenses for reimbursement. This grace period is known as a runout period.

An employee must have incurred the expense during the benefit year to qualify for reimbursements. However, this depends on the plan documents. For example, an organization might extend its health reimbursement deadline by implementing a 30-, 60-, or 90-day runout period after the benefit year, giving employees a larger window to submit any medical expenses they may have forgotten.

Declined reimbursement deadlines

Sometimes, employees may submit reimbursement claims for items or services that the organization or the IRS doesn’t allow under their benefit guidelines. If you determine the expense is ineligible under an HRA, you must notify the employee within 30 days.

If an employee still needs to include proper proof of purchase with the expense, you can request that they submit additional information to help you verify the request before you approve it. In these situations, you must give the employee 45 days to provide more details.

Compliance and reporting deadlines

Next, let’s review some of the compliance and reporting deadlines you need to know to avoid potential penalties when administering your HRA.

Summary plan description

A summary plan description (SPD) summarizes your benefit and outlines the plan's details and requirements. It's the primary way you’ll communicate rights and obligations to your current employees, so you should write it in plain language that your plan participants can easily understand.

For first-time HRAs, you must deliver the SPD within 120 days of establishing the plan. For newly eligible participants in an existing HRA, you must provide the SPD within 90 days of their first date of coverage under the plan.

You can distribute the plan summary to your employees by:

USPS First-Class Mail
Hand delivery at your worksites
Electronic delivery (as long as you give notice first)

You're not meeting your compliance requirements if you offer an HRA without an SPD. The Department of Labor can penalize you up to $110 per day if you don't provide one within 30 days of an employee's request.

When offering an HRA with PeopleKeep by Remodel Health, our platform automatically generates a plan document and SPD based on your benefit design details. Employees can access these documents from their PeopleKeep accounts.

Forms 1094 and 1095

If you’re an organization with 50 or more full-time equivalent employees (FTEs), known as an applicable large employer (ALE), using an individual coverage HRA (ICHRA) to satisfy the Affordable Care Act’s employer mandate, you must file Forms 1094-C and 1095-C. You’ll use Form 1095-C to show you offered your employees an affordable ICHRA benefit¹.

You must provide your employees with a completed Form 1095-C by January 31 each year. You should also summarize your 1095 forms on Form 1094-C, which is due by March 31 if filing electronically. You can face costly penalties if you don’t file Forms 1094 or 1095. So, work with a tax professional for additional guidance to complete them accurately and on time.

Organizations with fewer than 50 employees must also complete Forms 1094 and 1095. However, you’ll use Form 1094-B and 1095-B instead. These forms require fewer details because small employers don’t have to comply with the employer mandate.

In addition to federal compliance requirements, some states have their own health coverage reporting deadlines that employers must follow. States like California, New Jersey, and Rhode Island require employers to submit state-level versions of Forms 1094-C and 1095-C to verify that individuals had qualifying health coverage. These deadlines are often similar to the federal timelines, but the exact requirements can vary by state.

To learn more about Form 1095, check out our complete guide.

Form 5500 and the Summary Annual Report

Form 5500 is an annual report that includes information about a benefit plan's financial condition and operations, which organizations file with the Department of Labor. All organizations offering benefits subject to the Employee Retirement Income Security Act of 1974 (ERISA) with 100 or more participants must file Form 5500.

Because HRAs are subject to ERISA, you must complete Form 5500 if you have 100 or more participants at the beginning of the plan year.

Form 5500 is due for most organizations on the last day of the seventh month following the plan year. For calendar year plans starting January 1 each year, this is July 31. You can request extensions of up to two and a half months by filing Form 5558 with the IRS before the deadline.

The Summary Annual Report summarizes Form 5500. You must distribute this report to plan participants within nine months after the plan year ends. For calendar year plans, this is September 30.

90-day notification period

Federal guidelines recommend that you notify employees at least 90 days before the start of a new plan year for any employee currently enrolled in a qualified small employer HRA (QSEHRA) or ICHRA. If you’re offering the benefit to a newly eligible employee, like a new hire, you must give notice on or before the first day they’re eligible to participate.

In the case of an ICHRA, the 90-day notice gives employees enough time to decide whether to opt in or out of the benefit. You must provide a written notice every year you offer the ICHRA.

If you offer HRA through PeopleKeep by Remodel Health, our administration software automatically sends email notifications to employees based on the schedule you set.

The 60-day notice of material modification

Like many other self-insured plans, some types of HRAs, like an integrated HRA, require you to distribute a summary of benefits and coverage (SBC) to your employees. SBCs are short documents that describe your health benefit in plain language and help employees compare individual health insurance coverage at a glance.

If you make any plan changes that affect the SBC's content, it’ll trigger the 60-day notice requirement.

Also known as the 60-day notice of material modification, the Affordable Care Act (ACA) requires employers to provide employees with at least 60 days' advanced notice before making any material modifications to their health plan.

These modifications can include changes to:

Coverage
Cost-sharing
Network providers
Any other plan terms that may impact an employee's benefits

Sending this notice is mandatory; otherwise, you may experience steep fines. However, there are situations where you may be exempt from the 60-day notice.

Learn more about the 60-day notice of material modification in our blog.

PCORI fees

All employers offering a QSEHRA or an ICHRA must pay a yearly fee to the Patient-Centered Outcomes Research Institute (PCORI) and submit Form 720. This fee applies regardless of your company’s size.

For plans ending on or after October 1, 2025, and before October 1, 2026, the PCORI fee is $3.84 per covered life. The fee for plan year ending on or after October 1, 2024, and before October 1, 2025, the PCORI fee is $3.47 per covered life².

This fee is due by July 31 following the plan year. Initially, this fee was to expire in 2019. However, the Further Consolidated Appropriations Act of 2020 extended it through 2029³.

Get all the details on Form 720 and PCORI fees in our article.

W-2 reporting

Employers must report QSEHRA allowances on employees’ W-2 forms using code FF in Box 12. QSEHRA allowances are exempt from federal income and payroll taxes for both the employer and the employee. It is also free of income tax as long as the employee has minimum essential coverage (MEC).

Unlike the QSEHRA, there are no W-2 reporting requirements for the ICHRA. However, you must follow other reporting requirements if you offer an ICHRA, so check the rules to avoid costly fines.

Need help keeping track of deadlines?

If you use HRA administrative support software like PeopleKeep, you and your employees don’t have to keep track of reimbursement deadlines on your own. PeopleKeep helps thousands of organizations across the U.S. track reimbursement amounts and requests, and even sends automatic reminders.

What’s more, you’ll have access to our award-winning customer support team whenever you or your employees have questions about which healthcare costs qualify, when deadlines are coming up, or anything in between.

Conclusion

An HRA is an excellent way for organizations to offer their employees a personalized and flexible health benefit. But it’s your job to make sure important deadlines don’t pass you by. With PeopleKeep’s help, you can take a backseat while our benefits administration software and customer support team do all the heavy lifting.

Schedule a call with an HRA specialist to learn how we can help you set up and manage your health benefits.

This blog article was originally published on February 16, 2024. It was last updated on March 27, 2026.