4 Reasons to Avoid HRA Debit Cards

New Call to action

SUBSCRIBE

The Zane Employee Health Benefits blog covers all of employee health benefits - Defined Contribution, private exchanges, individual health insurance, small business health benefits, HRA, and premium reimbursements. Join thousands of others and subscribe now!

Subscribe to RSS feed Add us on Facebook! Follow us on Twitter

Subscribe by email

Your email:

Search

Current Articles | RSS Feed RSS Feed

4 Reasons to Avoid HRA Debit Cards

 

Many Third Party Administrators (TPAs) promote HRA Debit Cards (see Health Reimbursement Arrangements) as a hassle-free mechanism for employee payment of medical expenses.  However, employers should avoid using HRA debit cards because doing so is time-consuming, costly and unnecessary. Negative characteristics of HRA debit cards include:avoid resized 600

  1. Pre-funding of Contributions

  2. Manual Claim Requirements and Usage Restrictions

  3. Limited HRA Plan Design

  4. HRA Debit Cards Often Result in Pay and Chase

The "pay and chase" nature of HRA Debit Cards is best explained by the following example:

Mary is an employee of Employer X that uses a HRA Debit Card platform.  Mary goes to the doctor and is presented with a bill of $300 at the time of service.  Mary pays for the service in full ($300) using the pre-funded HRA debit card provided to her by Employer X.  Next, Mary's insurance provider sends her a bill for $200, incorporating the discounts that her insurance company had negotiated with her medical provider.  Mary then needs to submit a claim for the service.  She submits a claim for the $200 shown on the bill, but Employer X has already paid $300 from the HRA debit account.  It is now Mary's responsibility to contact the medical provider, obtain the dollar amount overpaid ($100), and provide it to Employer X. 

Employees who do offer an HRA without a debit card typically do not pay at the time of service and only request reimbursement using an Explanation of Benefits (EOB) from the insurer for the correct amount owed to the provider of service. 

HRA Debit Cards Require Unecessary Pre-funding of HRA Contributions

HRA Debit Cards require the employer to unnecessarily pre-fund contributions to the TPA. Employers should never pre-fund any portion of the HRA contribution.  This results in increased administrative (and operational) cost to the employer.

HRA Debit Cards Require Employees to Submit a Manual Claim

In order to maintain compliance, an employee must submit a manual claim form with proper substantiation after using the HRA debit card (Note: most major pharmacies are IIAS compliant and bypass the manual claim requirement, however the majority of health care providers do not bypass this requirement). This often results in employee confusion. For example, if an employee would like to use the HRA debit card for reimbursement of over-the-counter (OTC) drugs, he or she must obtain a doctor's prescription and receipt from the pharmacy and submit that information the third party administrator.  If the employee fails to submit the require information, the employer must "chase" the employee for the money.

Also, doctor offices, pharmacies, and other medical providers are not required to accept HRA debit cards. Employers often choose debit card HRAs to avoid out-of-pocket expenses for their employees, but the end result is usually confusion and added administration.

HRA Debit Cards Limit Employer Control and Plan Design

Employers who choose to utilize HRA Debit Cards may not restrict card usage to certain types of medical expenses.  They also cannot vary the contribution by employee classifications. These are lost HRA plan design features that often result in better benefits at lower costs.

hra-whitepaper-101

Note: This should not be taken as legal or tax advice.

subscribetoblogctablue

Comments



Some very
good information posted in the article as well as some very poor and inaccurate
information posted in this article regarding the use of the debit card. You
state the following:

"Also,
doctor offices, pharmacies, and other medical providers are not required to
accept HRA debit cards." - While pharmacies are not required to accept the
debit card, all national chains do accept the card along with the majority of
mom and pop pharmacies. Using an HSA style health plan with all expenses
subject to the deductible, the debit card is PERFECT in this situation as it
CAN BE CODED to only work for prescriptions and auto substantiate the claim.
The two major advantages to this are the employee does not have to pay for the
prescription with their own funds (many times they don't have the money to pay
for necessary prescriptions) and it eliminates the need for almost all
paperwork. 65% of claim activity are for prescriptions, so this vastly improves
the process.

S. Honig

Posted @ Friday, April 06, 2012 4:25 PM by Stephen Honig
Stephen,
You mentioned that there was inaccurate information in the post, but did not give an example. What is inaccurate?
Also your statement that 65% of HRA claim activity is for pharmacy is grossly inaccurate based on our data.  Please provide a source. Based on our client data, the vast majority of companies pairing an HRA with a group health plan design the HRA to exclude pharmacy expenses (and only reimburse deductible expenses).  The HSA-qualified plan pairing is the exception. 

Debit Cards work very well for HSA/FSA solutions, but not for HRAs for the reasons stated above. 

Posted @ Friday, April 06, 2012 4:25 PM by Zane Benefits


Section 3 below is not
an accurate statement if you are creating
the HRA over an HSA compatible plan and reimbursement deductible expenses
(which would include prescriptions).  In
the NJ and NY market space, this is a VERY common plan design.  Under this scenario, a debit card used to pay
Rx deductible expenses only would be a perfect plan design for the card.  Under the IIAS substantiation rules the card
could pay 100% of the Rx at the time of purchase (this would be the correct
carrier negotiated price, so no pay and chase here), the employee would not
have to lay our funds that many (who live paycheck to paycheck) would otherwise
not have the ability to pay for, and would (in 99% of the cases) eliminate the
need to provide any paper substantiation. 
The card would be coded to only allow a category 11 IIAS approved merchant
event, so only Rx would go through on a card transaction.  The card and Plan remain compliant (your
first sentence below was misleading as you indicate) “In order to maintain
compliance, an employee must submit a manual claim form with proper
substantiation after using the HRA debit card.” 
You also indicated below that “Also, doctor offices, pharmacies, and
other medical providers are not required to accept HRA debit cards.” – The fact
is that doctors, dentists, ophthalmologists, and hospitals are all exempt from
being required to participate in the IIAS system and do not provide any imbedded
coding so the card would NOT be appropriate in an HRA environment as you can
legally allow the card to be used at these merchants.  While a pharmacy is not REQUIRED to participate,
you are misleading in your article as it they are (as of 7/1/2009) required to participate
in the IIAS system if you want to use a debit card (unlike the other merchants
listed above).

 

The statistic I shared
with you that 65%of debit card transaction are prescription related is
predicated upon well accepted industry data and specifically our own data on
close to 1,000,000 claims processed. 
Obviously, HRA plan design is critical in the overall need and usage of
a debit card, so we may both be correct in our statements on percentage of
claims that are Rx related.  If the HRA you
are designing is a non HSA compatible plan with first dollar RX co-pay, there
is typically no need to have those claims run through the plan.  In our case, with the HSAc plan having such a
great rate reduction in our market place, it is a popular plan to use and turn
into the HRA.  Under this case,
significant claims come from the Rx and the 65% number is very accurate for
claims processed.

 

3. HRA Debit Cards Require Employees to Submit a Manual Claim

In order to maintain
compliance, an employee must submit a manual claim form with proper
substantiation after using the HRA debit card. This often results in employee
confusion. For example, if an employee would like to use the HRA debit card for reimbursement of over-the-counter
(OTC) drugs, he or she must obtain a doctor's prescription and
receipt from the pharmacy and submit that information the third party
administrator. If the employee fails to submit the require information, the
employer must "chase" the employee for the money.

Also, doctor offices,
pharmacies, and other medical providers are not required to accept HRA debit
cards. Employers often choose debit card HRAs to avoid out-of-pocket expenses
for their employees, but the end result is usually confusion and added
administration.



Posted @ Friday, April 06, 2012 4:25 PM by Stephen Honig
"Section 3 below is not
an accurate statement if you are creating
the HRA over an HSA compatible plan and reimbursement deductible expenses
(which would include prescriptions). "

 If the vendor is IIAS (which the vast majority of health care providers are not), then no manual claim is needed. We will add clarifying text. Thank you."

Regarding your claim data, are you including FSA/HSA claims in your sample set?  If so, that number would make sense... Debit Cards work very well for HSA/FSA solutions, but not HRAs.

Posted @ Friday, April 06, 2012 4:25 PM by Zane Benefits
Post Comment
Name
 *
Email
 *
Website (optional)
Comment
 *

Allowed tags: <a> link, <b> bold, <i> italics

More Info
Product
Customers
Across the Web
Contact Us
Disclaimer: The information provided on this website is general in nature and does not apply to any specific U.S. state except where noted. Health insurance regulations differ in each state. See a licensed agent for detailed information on your state. Zane Benefits, Inc. does not sell health insurance.