HRA Administration - 15 Features To Expect From Your Provider
The regulations governing Health Reimbursement Arrangements or HRAs are so flexible that there are literally hundreds of features you should consider when selecting an HRA software administration platform. See below for the top 15.
(1) Employee HRA Allowances
Employers should be able give employees their HRA allowances monthly, annually, hourly (tied to payroll or wages), or at any time on an exception basis—with automatic monitoring of HIPAA and ERISA discrimination compliance rules. Deferred allowances should be possible for new hires, and suspended HRAs should be allowed for former employees that employers hope to re-hire on a seasonal basis.
(2) HRA Claim Submission
Employees should be able to submit claims online, via fax, or mail to their Plan Supervisor, and immediately receive an email acknowledging their claim and providing an online link to monitor claim status. Medical receipts should be permanently available online for the convenience of employees desiring such access to copies of prescriptions, etc.
(3) HRA Claim Processing
Claims should be processed within 24 hours and employees should be able to inquire about their claim via online chat, email, fax, mail or telephone. No claim should be rejected for improper submission without multiple contacts from their Plan Supervisor. All employee contact should leave clear audit trails and meet appropriate regulatory guidelines (e.g. IRS, HIPAA, ERISA, SAS 70).
(4) HRA Claim Reimbursement
Employees should receive email notification when their claim is approved and again confirming when (and how) it is reimbursed. Reimbursement should be administrated individually or on a batch periodic basis via check, payroll addition, or direct deposit leaving a clear and permanently-available audit trail.
(5) HRA Employee Ledger
All employees should have access to an online ledger showing their current HRA balance, allowances, claims, and reimbursements including permanent storage of receipts, relevant tax information, and the ability to save or export their own medical information via the administration platform.
(6) Integrated Electronic HRA Plan Documents, SPD, and Employee Signature
The HRA Plan Document and HRA SPD (Summary Plan Description) should be electronically created, readily accessible online, and signatures should be collected electronically. Employers should be able to administer a change to benefits for any specific Class of Employees at any time and the electronic documents should automatically change and, where required, new electronic signatures should be collected when the employee is next online.
(7) HRA Classes of Employees
Employers should be able to instantly create online unlimited different Classes of Employees with each Class receiving different benefits by employee family status.
(8) HRA Categories of Expenses
For each Class of Employees, employers should be able to specify different benefits (annual maximum, coinsurance, first dollar coverage, etc.) for each Category of Expense such as Doctor Visits, Pharmacy, Preventative Care, Maternity, Dental etc.
(9) HRA Employee Enrollment
Employers should be able to instantly enroll or remove employees in real-time on an individual or batch basis, with automatic printing of employee Welcome Kits and other appropriate plan administration information.
(10) HRA Plan Setup
Employers should be able to completely set up and/or change both their HRA plan and their Plan Documents simultaneously online.
(11) HRA Reporting
Employers should be able to view all HRA Reimbursements by employee or by Class of Employees, and monitor in real-time de-identified Claim information for each Class of Employees by Category of Expense. Employees should be able to see 3-5 prior years of HRA expenses broken down by categories of expense.
(12) HRA Tax Forms and Information
All information for required administration reporting (e.g. 5500 for employers with more than 100 employees) should be available online in real time, and non-eligible HRA participants (e.g. independent contractors, owners of Sub S companies) should receive appropriate 1099 information.
(13) Personal Health Insurance Distribution
Employers using HRAs to administer pure defined contribution health plans (i.e. no group plan), or those using HRAs for less expensive dependent coverage, should have their HRA automatically provide their health insurer(s) a CRM (Customer Relationship Manager) to best serve their employees—including automatic notification to insurer(s) when an employee’s HRA plan status changes due to family additions, promotions, high claims, etc.
(14) HRA HSA-Compatibility
Employees should be unilaterally allowed to make their HRA administration HSA-compatible by requesting a higher annual deductible for traditional medical expenses while still retaining “first dollar” coverage for health insurance premiums, dental, vision, preventative care, and result of accidents. Employees should be able to turn off this feature at any time during a plan year if they need funds and no longer plan to make an HSA contribution that year, and turn HSA-Compatibility back on for subsequent years.
(15) HRA HIPAA and ERISA Compliance
The Employer should be automatically protected and the HRA administration made HIPAA Compliant through technology rather than the training of administrating employees. For example, employers should not be able to view HIPAA-protected employee information, and HRAs reimbursing for personal health policy premiums should automatically follow Department of Labor HIPAA and ERISA guidelines for employers allowing insurers access to their employees.
Note: This should not be taken as legal or tax advice.