Everything you need to know about health insurance
Monday, February 13th, 2012
HRA Plan Document Requirements
An HRA is aHealth Reimbursement Arrangement or Health Reimbursement Account that allows tax-free reimbursement of medical and insurance expenses.
The HRA Plan Document describes the HRA Plan's terms and conditions related to the operation and administration of the HRA Plan. 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.
The HRA Plan Document should contain:
Name of the HRA Plan 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
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