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TRANSCRIPT
February 16, 2017
Presented by:
Edward Fensholt JD and Lisa Carlson JD Compliance Services Division, Lockton Benefit Group
HSAs and HRAs:
The What, Why, How and More
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February 16, 2017
Presented by:
Edward Fensholt JD and Lisa Carlson JD Compliance Services Division, Lockton Benefit Group
HSAs and HRAs:
The What, Why, How and More
Click the Lockton logo to join
the webcast
Agenda
A Little GOP Health Reform Level-Set
Why HRAs and HSAs?
The Wild and Wooly World of HRAs
The Wacky, Wonky, Wonderful World of HSAs
Questions
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A Little GOP Health Reform Level-Set
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A Little GOP Health Reform Level-Set
Isobel Crawley: “What else could we drink to? We're going forward into the future, not back into the past." Dowager Countess: "If only we had the choice."
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A Little GOP Health Reform Level-Set
Repeal and Replace, er…Delay, er…Repair, er…Rescue and Rebuild?
Timing
It all begins in the House (White House or House of Representatives?)
A House divided: The Freedom Caucus vs. Paul Ryan
The Senate’s view: “What are you folks doing over there?”
What You Need to Know About a Replacement Bill
Taxation of employer-provided coverage
Tax equity?
The fog of war, and the deferred tax hit
Winners and losers
Tax Credits: conditional, or not?
The House GOP’s Healthcare Policy Brief today
Group markets vs. single payer
HSA turbocharging
A Word of Caution
Next Webcast on Repeal and Replace?
Pres. Trump’s Executive Order, and the IRS’s Initial Response
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Why HSAs and HRAs?
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Why HSAs and HRAs?
The Fight Against Cost, and the Drift Toward Consumerism
Higher and higher deductibles
More cost-shifting to enrollees
Push to provide greater transparency
Greater Cost Sharing Leaves Enrollees Vulnerable in an Ever-Widening Deductible and Cost-Sharing Corridor
Healthcare reimbursement vehicles help fill that corridor, on a tax-favored basis
Flexible spending accounts (FSAs): We won’t talk about this today, except indirectly
Health reimbursement arrangements: Lisa
Health savings accounts: Ed
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HRAs – The Good, the Bad and the Ugly
Overview
HRA 101
The Good and the Bad: HRA regulatory scheme under ACA
The Good: Integrated HRAs
The Bad: Stand-alone HRAs
The Ugly: Other ACA issues with HRAs
Why offer an HRA?
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What Is An HRA?
HRA 101
HRA means “Health Reimbursement Arrangement”
Employer-financed program where the employee can get reimbursed for tax-qualified medical expenses (or some subset of qualified medical expenses).
Employer payment plan (EPP) = HRA for reimbursement of an employee’s after-tax premium payments for medical coverage
HRAs are neither HSAs or health FSAs
An HRA may be structured under plan terms to allow unused monies to rollover into future (not required).
HRAs may ONLY be funded only with employer contributions.
Benefits paid from an HRA are non-taxable to the employee and are deductible by the employer.
HRAs are considered to be self-funded group health plans.
HRAs can operate in conjunction with health
FSAs. However, the plan documents must specify
which program pays first to avoid confusion.
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HRA 101
Claims substantiation is a requirement for establishing a permissible HRA.
Post-ACA, there are two three types of HRAs:
Integrated HRAs (OK for active employees)
“The Good HRA”
Stand-alone HRAs (generally cannot be used for active employees)
“The Bad HRA”
QSEHRA (looks like a stand alone HRA)
Allows small employers to reimburse individual premium.
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Why the Added Complexity Post-ACA?
Feds do not want to allow any type of “dumping” on the public insurance exchanges/marketplaces.
Guidance from agencies tailored to prohibit any type of employer reimbursement of premium payments for health coverage for active employees (“evil HRA”).
Either tax-free or after-tax
Logic: HRA itself is a group health plan, and as such is subject to the ACA insurance mandates, including the prohibition on dollar limits.
By design, HRA has dollar limits. Therefore, nonconforming group health plan subject to excise taxes under the Tax Code.
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The Good HRA – Integration is Key
Requirements for Integration (The Good HRA)
The employer must offer other group health coverage to the employee.
Something more robust. An excepted benefit such as most dental and vision plans or most health flexible spending accounts are not considered to be other group health coverage.
The HRA ay be provided only to an employee that is actually enrolled in the other group health coverage.
The terms of the HRA must reflect that only employees enrolled in other group health coverage are eligible for HRA benefits (the other group coverage doesn’t have to be the plan offered by the employee’s employer).
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Requirements For Integration (The Good HRA)
An HRA may reimburse spouse or dependent medical expenses (even if not covered under the current employer’s plan).
BUT -- An employee must attest to the fact that the spouse and/or or dependent has other group health coverage that the HRA can be integrated with.
If the group health plan does not meet minimum value, the HRA’s can reimburse only one or more of the following: co-payments,
coinsurance,
deductibles,
premiums under the other group coverage, and
medical care that does not constitute an “essential health benefit” under the ACA
BUT -- If the other group coverage supplies at least “minimum value” coverage (coverage with a least a 60 percent actuarial value), there is no such limitation on reimbursements.
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Requirements For Integration (The Good HRA)
The HRA must permit a covered employee or former employee to choose, at least annually, to permanently opt out of the HRA.
This same opt-out offer must be made at termination of employment unless the HRA balances are automatically forfeited upon termination.
Opt out is required because an HRA alone is MEC and could affect an individual’s eligibility for premium tax credits.
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The Bad HRA (and its Exceptions)
When is an HRA Bad?
A stand alone HRA may not be offered to an active employee to pay medical expenses or premium.
But, don’t forget the new small employer option to pay premium through a QSEHRA (discussed later).
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Permissible Stand-Alone HRAs
Retiree Only HRA
HRAs that provide benefits only upon retirement may stand alone -- but HRA coverage will disqualify the retiree from getting a tax credit if he or she purchases coverage on an insurance exchange. The Retiree must be allowed to opt out.
Limited use HRA (for actives or retirees)
An HRA that only reimburses for dental and vision expenses or other excepted benefits, or EPPs that only reimburse for dental and vision or other excepted benefit premiums.
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QSEHRA – Relief for Small Employers
Qualified Small Employer Health Reimbursement Arrangement (QSEHRA)
New option passed under 21st Century Cures Act - not technically an HRA as it’s specifically not a group health plan.
Permits small employers (under 50 FTEs) to reimburse individual health insurance premium.
The employer may not sponsor another group health plan.
Affects employee’s entitlement to tax credit.
Somewhat onerous notice requirements apply.
It is estimated that at least 16% of small employers still reimbursed individual premium in 2015 (in violation of the ACA) according to the National Federation of Independent Business.
This new option provides offers relief to some employers in this position.
For more detail, see:
Congress Restores Premium Payment Plans for Small Employers
http://www.lockton.com/insights/post/congress-restores-premium-payment-plans-for-small-employers
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Other ACA Issues With HRAs
The Ugly – Penalties for Noncompliance?
ACA Violation: An excise tax of:
$100 per day per occurrence
Results in an annual penalty of $36,500 per eligible employee.
COBRA Violation:
An HRA may also be subject to excise taxes resulting from a failure to properly offer COBRA.
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ACA Issues Affecting HRAs
W-2 health values: An employer may, but is not required to, include HRA coverage in the health plan values shown on the employee’s W-2.
SBCs: An integrated HRA benefit must be described somehow in the major medical plan’s SBC.
Stand-alone, retiree-only plans—whether benefitting pre-65 or post-65 retirees, or both—dodge the SBC requirement because they are treated as “excepted benefits” and thus are not subject to the SBC requirements.
PCORI fee: This fee does not apply to separate HRAs where the HRA and the allied medical plan are self-insured and have the same plan year.
Otherwise, the HRA sponsor owes the fee with respect to the HRA, but pays only for covered employees and retirees (not dependents).
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ACA Issues Affecting HRAs
Transitional reinsurance fee (TRF): This fee does not apply to integrated HRAs.
Stand-alone HRAs may be subject to the fee unless an exception applies. The last TRF payment was due in 2016 but employers should amend if additional fees are due.
Cadillac tax:
HRA allocations are included in the tax calculation, but the IRS has yet to describe the mechanics and there is strong lobby to repeal.
ACA Tax Reporting (Forms 1095): An integrated HRA will not trigger a reporting requirement.
By contrast, an HRA that was integrated with another employer’s coverage (e.g., coverage under an employee’s spouse’s plan) or was not integrated with other coverage at all (e.g., a $5,000 HRA provided to certain retirees) would be self-insured MEC-or-better that is subject to the reporting requirement mandate.
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Other Laws Affecting HRAs
Other Laws Affecting HRAs
COBRA
Qualified beneficiaries must be offered the opportunity to pay premium to continue HRA coverage.
This can create confusion when a qualified beneficiary is a spouse or dependent. No real guidance has been offered in this area.
An annual applicable premium for HRA continuation should be established – the balance of the account may not be considered when assessing COBRA premium for an HRA.
HIPAA
Medical information received by the HRA as a group health plan is subject to HIPAA privacy and security rules.
Nondiscrimination Rules under IRC 105(h)
Medicare Secondary Payor Rules
ERISA (rules affecting group health plans)
Other Federal Laws such as the ADA and FMLA
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Why Offer an HRA?
Why Offer an HRA?
As an alternative to an HDHP when an employer contributes to an HSA:
Certain individuals may be ineligible to open an HSA (e.g.. Covered under Medicare or Tricare or because they have coverage under a spouse’s employer’s FSA)
So that they have the benefit of the employer contributions, an HRA can be offered as an alternative with a maximum annual reimbursement equal to the HSA contribution that would have otherwise been made.
To subsidize retiree health coverage:
An HRA can be offered to fund later health costs after termination of employment, particularly focused on subsidizing retiree health expenses.
To subsidize dental, vision or other excepted benefit coverage:
An HRA can be established to fund reimbursement for dental or vision premium or to supplement existing dental or vision coverage (as well as any other excepted benefit).
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The Wacky, Wonky, Wonderful World of HSAs
Background
HSAs are the most tax-favored savings vehicle ever designed by man.
Health savings accounts are, well, savings accounts, in the name of the employee, held at a bank or other trust company.
The HSA itself is not really an employer plan, although the group coverage that is offered in conjunction with an HSA is an employer plan.
People often refer to an “HSA plan.” They are referring to the group plan that is offered in conjunction with the HSA.
Fundamentally, an HSA is a reimbursement account, like a health FSA or HRA, but there are key differences between these programs . . .
Background
HSAs accept both employee and employer money.
HRAs cannot; FSAs usually reflect only employee money.
HSAs take both pre-tax and after-tax (deductible) contributions.
Unlike HRAs and FSAs.
HSAs hold real dollars, which in some cases are actually invested.
Unlike vast majority of HRAs and FSAs, which are typically notional accounts.
Background
HSA dollars may be withdrawn for any reason, at any time.
Only issue is taxation…tax free for withdrawals to reimburse medical expenses, otherwise usually taxable and subject to additional excise tax.
Unused dollars roll over from year to year.
Unlike FSAs (except for 2½-month grace period or $500 carryover).
HSA accounts are completely portable, after employment.
Unlike FSAs and HRAs (except to the extent COBRA applies).
Background
Employer need not (and should not) adjudicate claims.
Unlike FSAs and HRAs
Employees determine when to obtain a reimbursement from their HSAs, for what purpose, and whether to pay tax on the withdrawal.
Background
BUT there’s a price . . .
HSAs have a VERY complicated quid pro quo.
Difficult to understand
Difficult to explain to employees
Some of the complexity may be mitigated by GOP health reform (more on that later).
Still, they are the trendiest trend in consumer-driven health insurance.
Who Can Have an HSA?
Who Can Have an HSA?
Almost anyone, as long as specific requirements are met
Employees
Partners (but can’t participate in FSA or HRA)
More than two percent owners in S corporations (ditto)
LLC shareholders (ditto, if they’re treated as self-employed)
Sole proprietors (ditto)
Putting Money Into an HSA
Putting Money INTO an HSA
#1 Important Lesson:
There are specific rules about when an individual can put money INTO an HSA.
There are no restrictions or rules about when an individual can pull money out of an HSA.
But there are tax consequences to consider…
In other words: whether, at any moment in time, A person can put new money INTO an HSA has NOTHING to do with his or her ability to pull money OUT of an HSA.
Putting Money INTO an HSA
Must be considered an “eligible individual”
To be considered an “eligible individual” (and thus eligible to make HSA contributions), you must:
Be enrolled in a qualifying high deductible health plan (HDHP)—a special kind of health plan that satisfies specific requirements—and . . .
NOT BE enrolled in most other, non-HDHP coverage, either through the employer or someplace else (e.g., as a covered spouse under your spouse’s health plan).
Thus, the rules are designed to ensure you “feel the pain” in exchange for all the tax-favored goodness . . .
Not be entitled to (covered by) Medicare
Not be anyone’s tax dependent
The only person who needs to be an eligible individual is the one who owns the HSA.
It’s not disqualifying for the employee, for example, if the employee has HDHP coverage for himself and his spouse, and his spouse has self-only coverage under a non-HDHP.
On first day of the month . . .
Putting Money INTO an HSA
HDHP coverage must:
Be reasonably robust (must be relatively comprehensive, and supply significant benefits)
Dental and vision coverage won’t cut it
Have specific minimum high deductibles:
$1,300 for individual coverage (for 2017)
$2,600 for family coverage (for 2017)
Embedded deductibles may be a problem (see next slide)
Have out-of-pocket maximums that don’t exceed:
$6,550 for individual coverage (for 2017)
$13,100 for family coverage (for 2017)
Putting Money INTO an HSA
HDHP coverage must comply with the “not one penny” rule
No reimbursements/payments below the high deductible; no Rx, no office visits, no nothing . . .
Idea is to force the member to “feel the pain” of out-of-pocket expenses, so as to perhaps become a bit more circumspect about health care consumption.
Exception for some “preventive care”
In the case of family HDHP coverage, no reimbursement of any expenses for any family member until minimum family deductible is met (unless an individual deductible is embedded…but there are strict rules about this!)
Putting Money INTO an HSA
So . . . must be enrolled in HDHP coverage, and cannot have non-HDHP medical coverage.
Mere eligibility for other coverage, or Medicare is okay.
Spouse or dependent’s eligibility or enrollment in other coverage or Medicare is okay too…as long as it doesn’t cover the HSA owner.
Some other coverages are okay
Dental, vision
Coverage for accidents
Indemnity insurance plans paying a fixed amount per day of hospitalization
Putting Money INTO an HSA
But other coverages pose issues or outright problems
FSAs (unless “limited” or high deductible)
Mid-year HSA implementations pose problems
Note: You have FSA “coverage” if you’re enrolled under the program, even if only by a spouse, domestic partner or parent. The fact you don’t intend to submit claims, (or have a zero balance, except at year end) is not relevant
HRAs (same)
Medicare coverage
VA coverage (subject to 3-month rule, and special rule for treatment of service-connected disabilities)
On-site clinics providing “significant” benefits (Rx, primary care, etc.; okay to give allergy shots or immunizations, treat workplace injuries, give non-prescription meds, etc.)
Work-around: Make benefit “high deductible”, i.e., make the employee pay the full price
Telemedicine
Concierge medical?
GOP health reform proposals would fix some of this
Putting Money INTO an HSA
Coverage under a general purpose health FSA may interfere with a participant’s ability to contribute to an HSA 2013 health FSA carryover rule creates new problems for HSA eligibility
Type of FSA feature When FSA coverage ends
When HSA eligibility begins
FSA does not have either a grace period or a carryover
Coverage under the FSA ends on the last day of the plan year
The first day of the following plan year (if participant didn’t reenroll in FSA)
FSA has a grace period and balance is >$0 at plan year-end
Coverage under the FSA ends 2.5 months after the last day of the plan year
The first day of the first calendar month after grace period ends
FSA has a carryover provision and balance is >$0 at plan year-end
Coverage under the FSA ends 12 months after the last day of the plan year.
Appears participant will be ineligible for HSA contributions for the entire year; several workarounds; some GOP healthcare reform proposals would mitigate this
Putting Money INTO an HSA
Common issues with family coverage:
Employee has single coverage under HDHP, but is also covered under spouse’s non-HDHP plan
Employee has single coverage under HDHP, but spouse has a traditional FSA or HRA that would reimburse employee’s expenses
Employee has family coverage under HDHP (and no coverage under traditional FSA or HRA), spouse has employee-only non-HDHP coverage
Employee has single coverage under HDHP (and no coverage under traditional FSA or HRA), spouse has employee + children coverage under non-HDHP
Putting Money INTO an HSA
Maximum annual contribution
$3,400 if eligible individual has single HDHP coverage, $6,750 if it’s family HDHP coverage (for 2017)
For each month the person begins as an “eligible individual,” he accrues the right to make a contribution equal to 1/12th of this maximum . . . his annual maximum is then the sum of these monthly maximums…
Employee first becomes an eligible individual on March 1, 2017 and remains eligible through September. He is enrolled in employee-only HDHP coverage. His maximum contribution for 2017 is: 1/12th of $3,400 x 7 months = $1,983.
BUT WAIT! There’s a special “Deeming Rule”!
Are you an “Eligible Individual” on December 1? You win! You are deemed to have been an Eligible Individual all year, and can make the FULL annual contribution!
BUT . . . you must remain an Eligible Individual for the ensuing year!
Some GOP health reform proposals would eliminate this last wrinkle about having to maintain HSA eligibility for the ensuing year.
Putting Money INTO an HSA
Maximum annual contribution issues
Employee has employee-only coverage under HDHP, spouse has employee-only coverage under non-HDHP: Employee may open an HSA and fund to the single coverage maximum (because he has single coverage under the HDHP).
Employee has family coverage under HDHP, spouse has employee-only coverage under non-HDHP: Employee may open an HSA and fund to the family coverage maximum.
Employee has employee + spouse coverage under HDHP, spouse has employee-only coverage under non-HDHP: Employee may open an HSA and fund to the family maximum.
Employee has family coverage under HDHP, spouse has employee-only coverage under HDHP: Both may open HSAs, but together may only fund to the family maximum.
Putting Money INTO an HSA
Maximum annual contribution: Catch-up contributions
HSA rules permit employees age 55 and older to make special, additional contributions to their HSAs (assuming they’re otherwise eligible to do so). These are called “catch-up contributions.” The limit is $1,000.
Rule grants the special “catch up” right for a given year if the employee is at least age 55 at any point in the year . . .
If employee and spouse are both 55 and HSA-eligible, they may both make catch-up contributions to their respective HSAs; employee can’t put the $2,000 into his HSA, or vice versa; some GOP health reform proposals would fix this.
The catch-up contribution maximum accrues month-by-month too (e.g., 1/12th of maximum for each month the person is an “eligible individual), but the special deeming rule applies here.
Putting Money INTO an HSA
Maximum annual contribution: What’s included?
When determining whether an HSA has received the maximum allowable contribution, the account owner must AGGREGATE all contributions.
Employee and spouse (if both are eligible to make HSA contributions to their respective HSAs, up to the family coverage maximum) get ONE BITE at the maximum contribution apple each year . . . they may allocate the maximum between their HSAs, as they see fit.
IRS now recognizes same-sex spouses, so they are subject to this rule just like opposite-sex spouses.
Domestic partners get a better deal.
Putting Money INTO an HSA
Timing of contributions
No contribution permitted until HSA is “established.”
“Established” is a key concept; no tax-free withdrawals for reimbursement of medical expenses incurred before HSA is “established.”
IRS: HSA is established when “established” under state trust law; generally requires the account be funded (i.e., a contribution); but can’t fund it until an “eligible individual.”
So . . . employee should complete paperwork in advance, then fund the HSA, even if with just a few dollars, as soon as possible after he/she becomes an eligible employee.
Doing so allows the employee to start incurring medical expenses that would be reimbursable tax free, even though he may not start seriously funding the HSA for months or years into the future.
Putting Money INTO an HSA
Timing of contributions
Although the right to make HSA contributions accrues month-to-month (unless the deeming rule applies), the actual timing of the individual’s HSA contributions need not dovetail with the accrual of the right to make them.
So, the individual may:
Prefund the HSA.
Retro-fund the HSA, up to April 15 of the following year.
Retroactive funding may occur even if, at the time of the actual contribution, the individual is no longer eligible.
Putting Money INTO an HSA
Employer contributions
Rules on limits, etc. discussed to this point apply to – and are from the point of view of – the individual HSA owner.
Employers making contributions to employees’ HSAs, and/or allowing employees to make pre-tax contributions to HSAs through a cafeteria plan, might calculate an HSA contribution limit differently.
Employer + employee pre-tax contributions may be made based on employer knowing three things:
Employee has HDHP coverage under employer’s plan (and whether self-only or another coverage unit).
Employee does not have any impermissible non-HDHP coverage through the employer.
Employee will (or will not) have reached age 55 by year-end.
No withholding of income or employment taxes on employer HSA contributions or on employee pre-tax HSA contributions.
Employer and employee pre-tax contributions MUST BE REPORTED ON EMPLOYEE’S W-2 (Box 12); IRS instructions refer to “employer” contributions but that includes pre-tax employee contributions.
Putting Money INTO an HSA
Nondiscrimination in employer contributions
As long as employees may make their own pre-tax contributions to their HSAs through the employer’s cafeteria plan, nasty “comparability rules” (nondiscrimination rules) don’t apply (but cafeteria plan nondiscrimination rules apply, such as they are).
Changing the amount of employee pre-tax contributions
Pre-tax contributions to HSAs are not subject to the usual election rules – no limit on changes; if cafeteria plan has a limit, it must allow changes at least once a month.
IMPORTANT: All HSA contributions are non-forfeitable.
With very limited exceptions, once an employer puts a contribution in an employee’s HSA, CANNOT get it back.
Mistakes happen
See our Benefits Insight and Guidance on correcting excess and erroneous HSA contributions.
Taking Money Out of an HSA
Taking Money OUT of an HSA
Remember, you can ALWAYS withdraw HSA dollars, whether or not you’re eligible to put additional dollars into the HSA.
Can withdraw HSA dollars for any reason, no reason, or no good reason . . . only issue is taxability.
Taking Money OUT of an HSA
Reimbursement of medical expenses for –
Employee, spouse (including same-sex) and Tax Code “dependents” are tax free . . . if the expense was incurred on or after the date the HSA was established
No “age 26” rule here, for non-dependent adult children
“Medical expenses” include:
Section 213 expenses for “medical care” (but not OTC Rx since 2011)
COBRA premiums
Medicare premiums
Long-term care insurance
Retiree health insurance after age 65, but not Medigap
Health insurance premiums while drawing unemployment compensation
GOP health reform proposals would allow wider latitude for tax-free distributions
Taking Money OUT of an HSA
Other withdrawals are taxable.
Income tax
Subject to 20% excise tax if withdrawn prior to age 65, death or disability
Withdrawal by HSA account holder, who is not yet 65, to pay Medicare premiums for spouse, who is at least age 65, are taxable and subject to excise tax
HSA service fees/account maintenance fees
Debiting the HSA for these fees is not a “distribution” potentially subject to tax.
Other Interesting Issues
Talked already about common ones…mid-year HSA implementations, FSA grace periods and carryovers, etc.
See our Benefits Insight and Guidance on this issue
Mid-year coverage changes (employee-only to family, etc.)
Dealing with residual HRA balances upon HDHP implementation
Retroactive Medicare Part A coverage
Recent IRS confirmation of this issue; but how worried should we really be?
“Preventive care” including Rx
Voluntary benefits and “disqualifying” coverage
Employer informal reimbursements of deductibles
ERISA issues regarding employee contributions
Employer contributions: making the HSA look like an FSA
Deductible carryovers
Lockton Resources
Lockton Alerts
Employers with Health Reimbursement Arrangements - This One’s for You
http://www.lockton.com/insights/post/employers-with-health-reimbursement-arrangements-this-ones-for-you1
HRAs and Health FSA “Carryover” Rules: Year-End Issues You Need to Know
http://www.lockton.com/insights/post/hras-and-health-fsa-carryover-rules-year-end-issues-you-need-to-know
Updated FSA/HRA/HSA Grid
http://www.lockton.com/insights/post/updated-fsa-hra-hsa-grid
Benefits Insight and Guidance So You Want To Install An HSA-compatible Plan Midyear (But You Have A Health FSA
In Place)
So You Over-contributed To A Health Savings Account. Now What?
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Questions?
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Questions? Ask them on Twitter: #LocktonClass Follow us on Twitter @LocktonComply and @LocktonBenefits
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