This is an update to our December 2016 blog post (IRS Updates Will Impact School, City and County HRA Plans in 2017) regarding IRS Notice 2015-84 – Dependents seeking reimbursements from an HRA.
The Department of Labor, Health and Human Services and the Treasury released FAQ #37 on the implementation of the Affordable Care Act. The FAQ clarifies that an Health Reimbursement Arrangement (HRA) covering employees, spouse and eligible dependents may be considered integrated with a combination of group health coverage (i.e. the employee’s and spouse’s group health plans). Also the group coverage does not need to be under the same plan sponsor as long as it meets the integration requirements. Additionally, spouses and/or dependents are able to seek reimbursement from the participant’s HRA if the participant has self-only group coverage and the spouse and/or dependent have group coverage through a separate source. The employer may rely on “reasonable representation” of any employee that his or her spouse and/or dependents have group coverage.
For those clients with an Integrated HRA with National Insurance Services and MidAmerica Administrative & Retirement Solutions, the claim form has been updated to include an attestation that spouses and/or dependents have group coverage and are eligible for reimbursements.