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Enrollment season is just around the corner, so I thought I would repeat, in a condensed manner, the rules for health FSAs offered through cafeteria plans and a reminder about permissible HRAs.
There are just two rules to follow in order to offer health FSAs: Limited-purpose health FSAs may also be offered, perhaps in conjunction with HSAs, that provide for just vision and dental expenses.
Vision and dental expense reimbursement plans are excepted benefits. Acceptable integration methods are divided into two categories: An HRA cannot be integrated with individual policies. The MV not required method requires HRA benefits to be limited to co-payments, co-insurance, deductibles and premiums for group health plans and IRS d eligible medical expenses that do not constitute essential health benefits covered by the other group health plan.
Retiree HRAs and HRAs that provide excepted benefits such as vision and dental expenses may continue to be utilized by employers and do not have to meet the conditions noted above. HRAs that cannot continue include non-integrated arrangements and HRAs that are integrated with individual insurance policies or that pay premiums for individual health insurance policies.
There is, however, a transition period for ineligible HRAs that were in place as of January 1, ACA-compliant group health plans generally have a maximum day waiting period prior to enrollment. Have employers check both plan documents to ensure that employees are not eligible for health FSAs prior to being eligible for group health insurance plans.
Employers need to update their plan document before the end of their current plan year in order for employees to take advantage of this great benefit.
Check with your employers on all these important points and start out with appropriate, compliant flexible benefits.
No information contained herein is intended to be legal, accounting or other professional advice. We assume no liability whatsoever in connection with your use of or reliance upon this information. This information does not address specific situations. If you have questions about your specific situation, we recommend that you obtain independent professional advice.
She draws upon more than 25 years of experience with flexible benefits plans and tax laws to perform consulting services and monitor quality control. She is the lead instructor for the Section administrators training workshop. LeTourneau was one of the first people in the country to earn the Advanced Certification in Flexible Compensation Instruction designation sponsored by the Employers Council on Flexible Compensation.
She is a certified trainer in the ACFC program. LeTourneau can be reached by telephone at or by email at jan.
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