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Comparison
Chart of Flexible Spending Accounts
(FSAs) with
Health Reimbursement Arrangements
(HRAs)
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Questions
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FSAs
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HRAs
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| May
employees make pre-tax salary reduction
contributions? |
YES. |
NO.
Coverage must be paid for solely by
the employer. Salary redirection contributions
(either directly to the HRA or indirectly
to another arrangement) are strictly
prohibited. |
| May
unused coverage be carried over to subsequent
tax years? |
NO.
Unused coverage must be forfeited at
the end of the coverage period (which
is typically a calendar year). |
YES.
Unused coverage can be carried over
to subsequent coverage periods, even
if the coverage is in a subsequent tax
year. Coverage carried over may increase
the coverage limit available in subsequent
periods. |
| Must
the arrangement have a specified period
of coverage? |
YES. |
NO.
There is no required period of coverage.
Employers are free to fashion their
own coverage periods. For example, separate
coverage periods could be offered each
calendar quarter. |
| What
type of expenses may be reimbursed? |
Any
type of expense for medical care as
that term is defined under applicable
tax laws. No reimbursement is permitted
for premium payments for other health
coverage. |
Same
types of medical expenses that are reimbursable
under FSAs are reimbursable under HRAs.
Unlike FSAs, however, premium payments
for other health coverage are reimbursable.
For example,an HRA could be used to
pay premiums under a spouse's health
plan or pay premium's for coverage under
the employer's retiree medical plan. |
| May
premiums for long-term care insurance
be reimbursed under the arrangement? |
NO |
YES |
| Who
is entitled to receive reimbursement? |
Current
and former employees, their spouses
and dependents ( as defined under applicable
tax laws), and the spouse and dependents
of deceased employees. Self-employed
persons cannot be covered. |
Same. |
| Must
the maximum amount of reimbursement
permitted under the arrangement be available
at all times? |
YES.
The FSA must have a risk-shifting
element that makes the full amount of
coverage available even if the reimbursement
exceeds the participant's actual contributions
to the plan at the time of reimbursement. |
NO |
| Can
medical expenses incurred outside of
the period of coverage be reimbursed? |
NO |
Yes,
(1) if the claim was incurred after
the HRA was put into effect, and (2)
the individual was covered under the
HRA at the time the claim was incurred. |
| Do
the tax rules prohibiting discrimination
in favor of Key Employees and Highly
compensated employees apply. |
YES.
The arrangement cannot discriminate
(either in for or operation) with respect
to eligibility for coverage or for the
reimbursement benefits provided. |
Same
as for FSAs
Key
Employee & Highly Compensated
Employee Defined
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