Ashley Donohue – PrimePay https://primepay.com Thu, 14 Nov 2024 19:58:30 +0000 en-US hourly 1 https://wordpress.org/?v=6.7.1 https://primepay.com/wp-content/uploads/cropped-favicon-1-150x150.png Ashley Donohue – PrimePay https://primepay.com 32 32 HSA Contribution Limits for 2025 https://primepay.com/blog/hsa-contribution-limits/ Wed, 13 Nov 2024 14:36:00 +0000 https://primepay.com/blog/hsa-contribution-limits/ The IRS recently announced the updated Health Savings Account (HSA) contribution limits for 2025 along with the adjusted limits for corresponding High-Deductible Health Plans (HDHPs). The annual deduction limit on HSA contributions for a person with self-only coverage under a High-Deductible Health Plan for calendar year 2025 is $4,300 (up from $4,150), and a $8,550 […]

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The IRS recently announced the updated Health Savings Account (HSA) contribution limits for 2025 along with the adjusted limits for corresponding High-Deductible Health Plans (HDHPs).

The annual deduction limit on HSA contributions for a person with self-only coverage under a High-Deductible Health Plan for calendar year 2025 is $4,300 (up from $4,150), and a $8,550 (up from $8,300) annual deduction limit for a person with family coverage in a HDHP.

Before we dive deeper into the 2024 – Present Revenue Procedures, the following is a brief refresher on HSAs.

As explained by the IRS, a Health Savings Account (HSA) is a tax-advantaged trust or custodial account you set up with a qualified HSA trustee to pay or provide reimbursement for certain medical expenses you incur. In other words, the HSA was designed to pay for day-to-day medical costs via HSA funds that an individual or family member may incur while remaining tax-free.

The account is owned by the employee and money is deposited directly into the individual’s account.

Employees may make contributions in the form of lump sum contributions or pre-tax payroll deductions. An employer may also contribute to the account.

As soon as funds accumulate, they are available. This differs from a health flexible spending account (FSA) that has uniform coverage, in which the full balance is available on the first day of the plan year.

HSAs offer numerous tax benefits, but it’s important to understand the potential tax penalties associated with these accounts. One such penalty applies to excess contributions, which are contributions made above the annual contribution limit.

If employees contribute more than the allowable limit, you will be subject to a 6% excise tax on the excess amount. Additionally, any excess contributions made are considered taxable income in the year they are made. It’s important to educate your employees to keep track of contributions to avoid exceeding the limit and incurring these penalties.

Another tax penalty pertaining to HSAs relates to using the funds for ineligible expenses. Using HSA funds for non-qualified expenses before the age of 65 will lead to a 20% penalty on the amount used for such expenses. This penalty is in addition to any income tax owed on the withdrawn amount.

After the age of 65, the penalty for using HSA funds for ineligible expenses is reduced to the ordinary income tax rate. However, it’s essential to note that even after the age of 65, using HSA funds for ineligible expenses will still result in taxable income.

To avoid tax penalties, it is crucial to provide the proper information for employees to familiarize themselves with the eligible expenses for HSA funds and ensure that contributions do not exceed the annual contribution limit. By understanding these tax penalties, users can maximize the potential tax savings offered by HSAs.

 
2025

2024

Difference

HSA Contribution Limit


Single – $4,300


Family – $8,550



Single – $4,150


Family – $8,300



Up $150


Up $250


HSA Catch-Up Contribution (for individuals age 55 and older)

$1,000

$1,000

No change.

HDHP Maximum Out-of-Pocket


Single – $8,300


Family – $16,600



Single – $8,050


Family – $16,100



Up $250


Up $500


HDHP Minimum Deductible


Single – $1,650


Family – $3,300



Single – $1,600


Family – $3,200



Up $50


Up $100


It’s never too early to start thinking about future medical expenses, tax saving opportunities, and saving for retirement.

Remember, HSA contributions may be made through pre-tax salary reductions and/or on a post-tax basis, up to the maximum limit for that year. Post-tax contributions may be made up until the date an individual’s taxes are due.

Please read our disclaimer here.

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Section 125 Premium Only Plans (POP): What Employers Should Know https://primepay.com/blog/section-125-premium-only-plans/ Fri, 21 Jun 2024 15:36:00 +0000 https://primepay.com/blog/section-125-premium-only-plans/ When creating a competitive benefits package, HR leaders usually look to their company’s specific offerings. That’s a strong strategy but it isn’t the only way to retain your people and attract new talent.  You should also consider the actual structure of your benefits plan – specifically, whether a cafeteria plan that allows for pre-tax salary […]

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When creating a competitive benefits package, HR leaders usually look to their company’s specific offerings. That’s a strong strategy but it isn’t the only way to retain your people and attract new talent. 

You should also consider the actual structure of your benefits plan – specifically, whether a cafeteria plan that allows for pre-tax salary deductions for health and other benefits is beneficial for your employees and organization. While cafeteria plans can incorporate several benefit components, they can also be as simple as a premium only plan (POP).

A premium only plan (POP) falls within the Internal Revenue Code’s Section 125, which lets employees use some of their earnings before taxes to pay for group insurance and other pre-tax contributions. It’s the simplest form of a cafeteria plan and a smart way for employers and employees to save on taxes.

Beyond the umbrella term of health insurance premiums, POPs can encompass various insurance products (including group term life insurance, disability insurance, and even dietary supplements), provided they align with the cafeteria plan’s rules.

Imagine your ideal benefits plan. Does it involve saving everyone money, empowering employees to be their best selves, or elevating your company’s competitive edge?

If you answered any (or all), you’re in luck. A POP is a win-win scenario where employees gain access to a cafeteria plan without bearing the full brunt of associated costs, and employers amplify their benefits offerings.

Moreover, integrating a 125 cafeteria plan nurtures your workforce and signals that you’re committed to fostering a supportive and financially savvy work environment. Offering a POP allows you to:

  • Save everyone on pre-tax deductions: Employers realize 7.65% in FICA tax savings, and employees average 25% tax savings. 
  • Invest in your team’s financial well-being.
  • Set the stage for attracting the 80% of candidates who believe financial wellness is an integral part of a comprehensive benefits package
  • Provide a menu of benefits that employees can tailor to their unique needs, enhancing their satisfaction and loyalty. 

PrimePay Employee Benefits Summary with FSA

Allowing employees to select benefits on their own time and for their unique needs adds value to the employee experience and ensures people will choose the plans and pre-tax savings that are right for them.

A 125 plan should be a part of your strategic financial planning, as it offers businesses and their employees a wealth of potential tax savings (pun intended). By skillfully navigating payroll taxes, a POP plan strengthens the financial defenses of both parties against unnecessary tax liabilities.

Whether it’s a health savings account, a flexible spending account, or even Archer medical savings accounts, pre-tax contributions made to these vehicles under a Cafeteria Plan can significantly reduce the tax burden.

Employer Benefits: Reducing Overhead with POP

The POP plan is a practical approach to managing overhead costs for employers. By embracing this plan, you can effectively shrink your taxable payroll. The result? Substantial savings, especially for many employers within the professional services sector. 

For example, let’s say small company Jerry’s Jungle Gyms offers a premium only plan. A possible scenario may look like the following:

  • Each of the 20 employees chooses to contribute $3,000 pre-tax to their group health insurance through the POP. 
  • The collective reduction in taxable income can lead to an estimated annual tax windfall of $4,590, which provides a tangible impact of nontaxable benefits on Jerry’s company balance sheet.
  • Thus, Jerry’s offering of POP becomes a gesture of goodwill and a strategic move to retain talent and reduce costs.

How Employees Save Money with POP

Employees also find themselves in a favorable financial position using pre-tax dollars to pay for qualified medical expenses. By reducing their income taxes through pre-tax deductions, they witness a welcome boost in their take-home pay – a direct result of their lowered tax liabilities. 

Consider employee Susan, who earns an annual salary of $60,000. By participating in the POP and reducing her taxable income to $57,000, Susan could see her take-home pay rise by approximately $1,725. This example illustrates the tangible benefits of the premium-only plan, where saving money isn’t just a catchphrase but an actual outcome of strategic financial planning.

Tip: Focus on employees’ financial literacy. Because over 60% of people say improving financial literacy is their top educational priority, you’ll empower your employees to use your benefit offerings confidently and signal to top talent that you’re invested in their future.

While the benefits of a POP are clear, it’s essential to note potential drawbacks.

Employers must be vigilant in complying with the intricacies of Section 125 plans, ensuring that their POP plan is secured by formal written documentation and adheres to the stringent nondiscrimination rules. 

The ‘use-it-or-lose-it’ rule is another aspect that demands attention, particularly with Flexible Spending Accounts (FSAs), a feature that employers can implement in their Cafeteria Plan. Employers must convey the importance of this rule to employees effectively and the constraints on altering Cafeteria Plan elections mid-year, which are only permissible during qualifying life events. 

Tip: HR must use clear and repeated communication regarding benefits and financial resources. PWC found that only 68% of employees report using the financial wellness services their employer provides, indicating that most benefit reminders only happen during administration season instead of throughout the year. 

The Role of a Third-Party Administrator in Managing a Cafeteria Plan

We’re not going to lie: Navigating benefits and employee questions can be time-consuming and confusing, which is why the expertise of a third-party administrator is invaluable. Many third-party administrators guide employers and help them:

  • Create plan documents that comply with nondiscrimination rules and other regulations.
  • Communicate the intricacies of the Cafeteria Plan to their employees.
  • Educate participants on maximizing benefits. 
  • Conduct regular compliance reviews to ensure the plan remains up-to-date with any changes in legislation or IRS guidelines. 

Furthermore, some third-party administrators and/or benefits advisors can offer valuable insights into optimizing the plan’s structure to better align with your company’s overall benefits strategy. They can recommend adjustments that enhance the plan’s effectiveness and employee satisfaction by analyzing participation data and employee feedback. This continuous improvement cycle ensures that the POP remains a valuable asset in your company’s benefits portfolio.

While companies of various structures – from S corporations to non-profits – can sponsor a Cafeteria Plan, not all individuals within these entities are eligible to reap the benefits. For instance, owners, shareholders, and their families may find themselves on the outside looking in when it comes to participation.

S corporation shareholders with over a 2% stake encounter unique restrictions under a Cafeteria Plan These individuals and their immediate family members are barred from participating—a rule extending to the intricate web of relationships, including spouses, children, and grandparents. This limitation underscores the need for S corporations to carefully consider the implications of their ownership structure on their ability to participate in a Cafeteria Plan.

Keep an eye on these eligibility nuances to maintain a fair and compliant plan with IRS regulations.

Maximize Pre-Tax Savings with a Cafeteria Plan

It’s clear that Cafeteria Plans offer a compelling blend of tax savings, employee satisfaction, and compliance considerations. Whether you’re an HR leader looking for new ways to retain top talent or a business owner weighing the benefits of implementing a Cafeteria Plan, the takeaway is undeniable: they help build a thriving, financially healthy work environment for everyone involved.

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State-by-State Pay Stub Requirements https://primepay.com/blog/state-by-state-pay-stub-requirements/ Fri, 30 Jun 2023 20:48:00 +0000 https://primepay.com/blog/state-by-state-pay-stub-requirements/ Taking care of your employees is your best ticket to success within your small business. And there’s a lot that goes into that.  But arguably one of the most important decisions you’ll make with regards to your employees is how you’re going to handle payroll. More than 95.5 percent of employee’s wages are received through […]

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Taking care of your employees is your best ticket to success within your small business. And there’s a lot that goes into that. 

But arguably one of the most important decisions you’ll make with regards to your employees is how you’re going to handle payroll.

More than 95.5 percent of employee’s wages are received through direct deposit. The remaining employees receive a paper check (2.85%), a payroll card (..60%), or are paid by other methods (.5%). 

While many small businesses still choose to use paper checks for their payroll, the cost of issuing a check — $2.01 to $4.00 per check — makes this an expensive payroll option.

But do you have to use paper checks? What are your recordkeeping requirements? And most importantly, what pay stub laws do you need to know about in your state?

In this article, we’ll cover the basics of state-by-state pay stub requirements.

What is a Pay Stub?

Pay stubs are documents that provide employees with a detailed breakdown of their earnings and deductions. They serve as accurate records of total hours worked and total wages earned, helping employees keep track of their income.

Pay stubs are also essential for employers to comply with various labor laws and regulations.

A pay stub includes key information such as gross earnings, also known as gross wages or gross pay, which represent the total amount an employee earns before withholdings and deductions. 

It also shows the number of hours worked during a specific pay period and the hourly rate. Deductions, which are subtracted from the gross earnings, can include federal and state income taxes, Social Security and Medicare taxes, healthcare and retirement contributions, and any other voluntary deductions authorized by the employee.

Taxes withheld, including federal income tax and state income tax (if applicable), are listed on the pay stub, along with any other mandatory deductions such as unemployment insurance or workers’ compensation. The net income, the amount left after deducting taxes and other deductions, is the final figure displayed on the pay stub, representing the employee’s take-home pay.

In conclusion, pay stubs play a crucial role in providing employees with a comprehensive breakdown of their earnings and deductions. They serve as proof of income and ensure compliance with labor laws. It is important for employers to accurately generate pay stubs that reflect an employee’s wages, deductions, and net income.

Do I Have to Provide a Pay Stub?

Besides paychecks, small businesses need to know the requirements for pay stubs. According to the Fair Labor Standards Act (FLSA), employers are not required to provide employees with pay stubs. However, the FLSA does require that employers keep accurate payroll records, including of the number of hours worked and employee wages, as well as employee information such as name and social security number, address, and hourly rate of pay

State law gets more complicated. Each state has its own pay stub requirements that employers must follow. Employers that have staff in more than one state must follow the requirements of the state where each employee resides and works. Employees that work in multiple states might be subject to further regulations, depending on which states are involved.

Quick Tip: Be sure to stay in the know about any state-by-state minimum wage updates.

No matter what your situation, ensure you’re complying with state regulations before choosing how to go about paying your employees. According to IRIS FMP, these are the requirements by each state for the delivery of employee pay information.

All states fall into one of these categories for pay stub requirements

  • No requirement states
  • Access states
  • Access/print states
  • Opt-out
  • Opt-in

States That Do Not Require Pay Stubs

The following states do not require employers to provide a statement that details an employee’s pay information, though it’s a good practice to issue employee’s pay stubs regularly and aligned with your pay period. Because there’s no required format, an employer may deliver a pay statement electronically if the employer elects to provide pay stubs to employees.

  • Alabama
  • Arkansas
  • Florida
  • Georgia
  • Louisiana
  • Mississippi
  • Ohio
  • South Dakota
  • Tennessee

In states without a pay stub requirement, it’s up to the employer to decide what information to provide on the statement.

States Requiring Access Pay Stubs

The following states require employers to furnish or provide a statement with details of an employee’s pay information. There’s no requirement for the pay statement to be in writing or issued as paper pay stubs. A reasonable interpretation of this law suggests that an employer can comply with the pay stub requirements in these states by furnishing an electronic pay stub. Employees must be able to access the electronic pay stubs.

Note: While most states have adopted this interpretation, some state agencies may require additional features like the capability to print electronic statements. 

  • Alaska
  • Arizona
  • Idaho
  • Illinois
  • Indiana
  • Kansas
  • Kentucky
  • Maryland
  • Michigan
  • Missouri
  • Montana
  • Nebraska
  • Nevada
  • New Hampshire
  • New Jersey
  • New York
  • North Dakota
  • Oklahoma
  • Pennsylvania
  • Rhode Island
  • South Carolina
  • Utah
  • Virginia
  • West Virginia
  • Wisconsin
  • Wyoming

States Requiring Access or Print Pay Stub Options

These states require employers to provide a written or printed pay statement that details the employee’s pay information. The pay statements are not required to be delivered with the check or in another medium. 

A reasonable interpretation of the law says an employer in these states can furnish an electronic paycheck stub that employees can print, thereby complying with the pay stub requirements. Furthermore, employers must ensure their employees have access to electronic pay stubs and the capability of printing electronic statements.

Note: Most state agencies have adopted this interpretation. However, some state agencies may vary. Those agencies have offered an interpretation that might include additional requirements — such as an employee’s consent to receive the pay stub electronically. These states include:

  • California
  • Colorado
  • Connecticut
  • Iowa
  • Maine
  • Massachusetts
  • New Mexico
  • North Carolina
  • Texas
  • Vermont
  • Washington

States Requiring Opt-Out Options

Some states require employers to provide employees with the ability to opt out of any paperless pay program it offers. This generally applies to cases where the employer rolls out a system to furnish electronic pay stubs. The following states are opt-out states, meaning, an employee that opts out of electronic delivery would begin receiving their paper paycheck stub once again. 

  • Delaware
  • Minnesota
  • Oregon

States Requiring Opt-In Options

Currently, Hawaii is the only opt-in state that requires employee consent before an employer implements an electronic paperless pay system. Employers in Hawaii must provide a written or printed pay statement with details of the employee’s pay information unless the employee agrees to receive their pay statement electronically.

Check with each state’s taxing authority to make sure you follow their rules and follow up each year to ensure you have the latest requirements. You can find a list of every state’s online tax agency at the Federation of Tax Administrators.  

Get in Touch

While there’s no federal law that requires pay stubs, there are state laws you must follow and ensure you meet all of the pay stub requirements. Failure to comply with your state regulations can add up to stiff fines — and that’s an expense your small business doesn’t need. Fortunately, PrimePay is here to help make payday a breeze. 

With PrimePay’s payroll software and payroll service solutions, you can easily adhere to state payroll requirements. PrimePay helps you run payroll accurately and on time, and it ensures compliance with all payroll-, human resources-, and tax-related laws and regulations. 

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How to Know If Your Employee Is HSA Eligible https://primepay.com/blog/how-to-know-if-employee-is-hsa-eligible/ Sat, 22 Oct 2022 00:58:00 +0000 https://primepay.com/blog/how-to-know-if-employee-is-hsa-eligible/ In the past, we’ve discussed how contributing to a health savings account (HSA) or allowing employees to contribute to their HSAs pre-tax through an employer’s Cafeteria Plan can lead to terrific tax savings for both the individual account holder and sponsoring employer.   As a refresher, HSAs allow individuals to contribute money (up to a […]

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In the past, we’ve discussed how contributing to a health savings account (HSA) or allowing employees to contribute to their HSAs pre-tax through an employer’s Cafeteria Plan can lead to terrific tax savings for both the individual account holder and sponsoring employer.  

As a refresher, HSAs allow individuals to contribute money (up to a maximum amount set annually by the IRS) to be spent tax-free on qualified medical expenses. Unlike health flexible spending accounts (health FSAs) and health reimbursement arrangements (HRAs), HSAs are owned by the participant; this means that funds roll over indefinitely and the account is portable.

Eligibility Rules

While the decision to contribute to an HSA may sound like a no-brainer, there are strict eligibility rules that employers and participants must keep in mind to avoid making excess contributions. It is important to note that HSA eligibility is determined on a monthly basis and the rules relate to whether an account holder is eligible to contribute to the account, not whether they can receive tax-free distributions; if there are accumulated funds in an HSA, the account holder always has access to those funds and is able to receive tax-free distributions for qualified expenses.

In general, an individual is eligible to contribute to an HSA if they are covered under a qualifying high-deductible health plan (QHDHP) with no impermissible coverage, cannot be claimed as a tax dependent on another taxpayer’s federal income tax return, and are not entitled to Medicare. A QHDHP must meet certain minimum deductible and maximum out-of-pocket limits.

Minimum Deductible and Maximum Out-of-Pocket Expenses for QHDHPs

The 2020 QHDHP minimum deductible and maximum out-of-pocket limits are: 

While determining whether a plan qualifies as a QHDHP may be easy, it may be more difficult to determine whether an employee is enrolled in impermissible coverage or has their HSA eligibility disrupted by Medicare entitlement. In general, it’s the account holder’s responsibility to determine whether they are eligible to contribute to an HSA.

Let’s break down a few common types of impermissible coverage.

General Purpose FSA/HRA

The most common disruptor of HSA eligibility is impermissible coverage in the form of a general-purpose health FSA or HRA. An otherwise HSA eligible individual will be ineligible to make HSA contributions for any month that they are enrolled in, or covered under, a general-purpose health FSA or HRA that pays first-dollar coverage.

This issue can arise when an employer sponsors multiple pre-tax benefits, including an HSA, health FSA, or HRA, but it is more common when an employee is covered under a spousal employer’s general-purpose health FSA or HRA which permit reimbursement for §213(d) expenses incurred by the employee, their spouse and dependents.

When an employer does sponsor multiple accounts, an employer can design their health FSA or HRA as either a post-deductible or limited purpose benefit to maximum tax savings and avoid HSA disruption. A post-deductible benefit will not reimburse expenses until after the minimum QHDHP deductible is met. A limited purpose benefit would only reimburse preventive care, dental or vision expenses.

VA Benefits

HSA eligibility may also be disrupted if an individual receives medical benefits from the Department of Veterans Affairs (VA). In general, an individual is ineligible to contribute to an HSA for any month that they have received VA medical benefits (other than allowable preventive care, dental or vision coverage) at any time during the previous three months, unless such care was in connection with a service-connected disability (i.e., a disability incurred or aggravated in the line of duty in the active military, naval or air service).

For example, if an employee receives VA benefits in January (for medical care not related to a service-connected disability), they would be ineligible to make HSA contributions for the months of January, February, March, and April. Assuming that the individual does not receive any VA medical benefits in the months of February, March, and April, they would then be able to resume making HSA contributions in May.

Note that this rule does not apply to TRICARE. Any individual receiving benefits under TRICARE is not eligible to contribute to an HSA (even if they are also enrolled in a QHDHP), because TRICARE does not meet the minimum annual deductible requirements.

Medicare

Medicare entitled individuals (i.e., eligible for and enrolled in Medicare) are ineligible to contribute to an HSA. While this rule may seem easy, the biggest hurdle in determining HSA disruption due to Medicare eligibility arises from retroactive Medicare entitlement. Medicare entitlement can be delayed when an employee works past age 65 or has a spouse that is still working (so they continue to be enrolled in an employer’s group health plan).

When they do sign up for Medicare coverage, that coverage will be retroactive six months prior to the month in which they applied for benefits (but no earlier than their first month of eligibility). Although they may not initially enroll until later in their initial enrollment period or during a special enrollment period, they will be ineligible to make HSA contributions for all months that they become retroactively entitled to Medicare benefits. Because of this, HSA account holders planning to enroll in Medicare must be careful to adjust their HSA contributions to account for the retroactive enrollment.

PrimePay Can Help Guide You Through HSAs

These rules do not encompass all of the eligibility requirements for HSA individuals and other plan designs or benefits may impact HSA eligibility. PrimePay is here to help answer all your questions about HSAs including HSA eligibility for employees.

Schedule a call today

Please read our disclaimer here.

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Health Reimbursement Arrangements (HRA): Which One Should I Offer? https://primepay.com/blog/hra-which-one-should-i-offer/ Wed, 23 Mar 2022 01:01:00 +0000 https://primepay.com/blog/hra-which-one-should-i-offer/ With six health reimbursement arrangement (HRA) plan types, many benefit broker consultants and employers may be asking the following question: Which HRA plan should I offer? But before we dive into the details, let’s cover what health reimbursement arrangements (HRA) are. What are HRAs? Defined by the Centers for Medicare and Medicaid Services (CMS), “health reimbursement […]

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With six health reimbursement arrangement (HRA) plan types, many benefit broker consultants and employers may be asking the following question: Which HRA plan should I offer?

But before we dive into the details, let’s cover what health reimbursement arrangements (HRA) are.

What are HRAs?

Defined by the Centers for Medicare and Medicaid Services (CMS), “health reimbursement arrangements (HRAs) are a type of account-based health plan that employers can use to reimburse employees for their medical care expenses.”

An HRA is a type of account-based group health plan funded solely by employer contributions. No salary reduction contributions or other contributions by employees are permitted. These plans often reimburse deductibles, copays, coinsurance, and prescription out-of-pocket costs.

Now, it’s important to note that there are currently six different plan types for HRAs, two of which were introduced on Jan. 1, 2020.

What are the six HRA plan types?

The six different plan types for HRAs are structured as follows:

  1. An HRA integrated with a group health plan.
  2. Limited-Purpose HRA: Dental, vision and preventative care expenses only.
  3. Retirement HRA.
  4. Qualified Small Employer HRA (QSEHRA).
  5. Individual Coverage HRA (ICHRA).
  6. Excepted Benefit HRA (EBHRA).

Let’s review each one to help you decide which works best for your organization.

1. An HRA integrated with a group health plan.

To put this type of HRA into perspective, let’s say an employer chooses a high deductible health plan (HDHP) with a $2,000 deductible for a single employee, which results in a lower premium.  The employer realizes that covering medical expenses out of pocket is a very high burden for the employee, and they decide to open an HRA to help reimburse deductible expenses. To keep the employer’s exposure to a minimum, the employee will be responsible to pay the first $500 of the deductible with the employer covering the remaining $1,500.

For an employer to offer this type of HRA, the HRA must be paired with a group health plan to satisfy the requirements of health care reform. Employers that do not sponsor a group health plan are not eligible to sponsor this type of HRA.

2. Limited-Purpose HRA.

Limited-Purpose HRA may only reimburse vision, dental and preventative care expenses.

An employer can offer this type of HRA in conjunction with a group HDHP. This type of HRA is also compatible with a Health Savings Account (HSA).  If you currently offer an HSA to your employees, this type of HRA might be right for you.

3. Retirement HRA.

retirement HRA reimburses medical expenses incurred after retirement. This type of HRA is only available to employees once they have retired.

4. QSEHRA

A Qualified Small Employer Health Reimbursement Arrangement (QSEHRA) is a tax-deductible benefit that allows more flexibility for employers who may not be able to afford traditional group health coverage; Similar to integrated HRAs, it’s owned and funded by the employer.

According to the U.S. Centers for Medicare & Medicaid Services, “Certain small employers—generally those with less than 50 employees that don’t offer a group health plan—can contribute to their employees’ health care costs through a Qualified Small Employer Health Reimbursement Arrangement (QSEHRA).”

Below are some additional details:

  • Employers are only eligible to sponsor a QSEHRA if they do not sponsor any other form of group health plan (including dental, vision, and health flexible spending accounts) and employees must be enrolled in some form of minimum essential coverage (MEC) to be eligible for reimbursements.
  • Employers must provide the benefit on the same terms to all eligible employees; maximum reimbursement amounts may vary only based on age or family size.
  • QSEHRA is limited in 2021 to $5,300 for single only and $10,700 for family coverage.

5. ICHRA

According to the U.S. Centers for Medicare & Medicaid Services, an individual coverage Health Reimbursement Arrangement (ICHRA) “is an alternative to traditional group health plan coverage to reimburse medical expenses, like monthly premiums and out-of-pocket costs like copayments and deductibles.”

ICHRAs are more flexible than QSEHRAs with no limit on the reimbursement amount or company size.

Common qualifying expenses can include individual insurance premiums, copays, deductible payments, coinsurance, doctor’s office visits, exams, lab work, hospital visits, and prescription drugs.

Employers of any size may offer an ICHRA including applicable large employers (ALEs) who are subject to the employer mandate. This is different than QSEHRAs, which may also reimburse individual medical premiums, but are limited to non-ALEs who do not offer any other form of group health plans (including dental, vision, and health flexible spending accounts). In fact, a large employer can satisfy both sections of the employer mandate (i.e., the offer of coverage and affordable/minimum value requirements, subject to special rules and calculations) by offering a standalone ICHRA to their full-time employees or offering an ICHRA alongside a traditional group health plan (to different classes of employees).

Below are some additional details:

  • ICHRAs can be used to reimburse premiums for individual health insurance by employees not offered coverage under an employer group health plan.
    • This is useful if an employer offers a group health plan but has an employee class carved out from eligibility under their plan, like part-time or seasonal employees.
  • Eligible employees must be enrolled in either individual medical coverage or Medicare.

6. EBHRA

An excepted benefit HRA (EBHRA), provides a sizeable employer-funded account while allowing employees to enroll in their choice of primary health coverage, if any. In fact, employees eligible for the EBHRA may choose not to enroll in any other form of coverage, and to participate in the EBHRA as a completely standalone benefit. For 2021, the maximum reimbursement amount is $1,800.

According to the U.S. Centers for Medicare & Medicaid Services, “this type of HRA isn’t allowed to reimburse premiums for individual coverage, traditional group health plans (other than COBRA or other continuation coverage), or Medicare.”

Employers of any size may offer an EBHRA, including applicable large employers (ALEs) who are subject to the employer mandate. Unlike ICHRAs, the employer must also offer all EBHRA-eligible employees a traditional group health plan in addition to the EBHRA; therefore, an ALE would not be able to satisfy the employer mandate solely by offering an EBHRA.

Conclusion.

When deciding which type of HRA to offer your employees, it’s important to speak with a professional to determine which plan is best for your organization. As an additional resource, the U.S. Centers for Medicare & Medicaid Services put together a comprehensive chart to assist with decision-making when it comes to exploring coverage options. Click here to view the chart.

This article also includes excerpts from our blogs “HRAs: The Good, the Basics & the Savings”. Click the below links to read more scenarios and advantages of each plan type, as well as additional employer information.

How PrimePay can help.

PrimePay can administer pre-tax benefits for your company, including HRAs, HSAs, and FSAs. When you choose PrimePay’s pre-tax benefit plan administration, you receive a dedicated service team, access to our support portal, automated claims processing, and a PrimePay debit card and mobile app.

Schedule a call today

Please read our disclaimer here.

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5 Common Compliance Issues for HRAs https://primepay.com/blog/5-common-compliance-issues-for-hras/ Fri, 26 Feb 2021 20:06:00 +0000 https://primepay.com/blog/5-common-compliance-issues-for-hras/ A Health Reimbursement Arrangement (HRA) is a tax-favored, employer-funded arrangement that pays for or reimburses the qualified medical expenses of an employee and/or his or her spouse and dependents. The following is a list (not comprehensive) of common compliance issues regarding HRAs. PrimePay is in a position to help with all of them; learn more about that […]

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A Health Reimbursement Arrangement (HRA) is a tax-favored, employer-funded arrangement that pays for or reimburses the qualified medical expenses of an employee and/or his or her spouse and dependents.

The following is a list (not comprehensive) of common compliance issues regarding HRAs. PrimePay is in a position to help with all of them; learn more about that at the bottom of this post.

Compliance Issue 1 – ERISA

HRAs are employee welfare benefit plans subject to ERISA. While many of ERISA’s requirements can be addressed up front in the creation of the plan, Plan Sponsors also must comply with ERISA’s Claims Procedures and Appeals Rules as well as the Record Retention rules.

Compliance Issue 2 – SBC Distribution

Also as ERISA plans, HRAs are subject to the ACA’s Summary of Benefits and Coverage (SBC) requirement. SBCs describing the benefits provided by the HRA must be provided to all plan participants.

Compliance Issue 3 – PCORI Fees

All HRA Plan Sponsors must file IRS Form 720 and pay the new PCORI Tax each year on or before July 31st. These fees apply to policy and plan years ending after October 1, 2012 and before October 1, 2019 (i.e., for seven full policy or plan years). For calendar-year plans, the fees would apply for calendar plan years 2012 through 2018.

Compliance Issue 4 – HIPAA

Health Insurance Portability and Accountability (HIPAA) and the related Health Information Technology for Economic and Clinical Health (HITECH) rules impose numerous requirements to protect health information used in the administration of HRA plans. PrimePay incorporates the HIPAA / HITECH rules into our operations and communications with clients and plan participants.

Compliance Issue 5 – COBRA

For certain plans, a special exception may apply where the employer is not required to offer COBRA coverage or can limit the duration of COBRA coverage to the plan year in which the qualifying event occurs. HRAs will rarely qualify for the special exception. So, in general, employers with HRAs are required to offer COBRA coverage to qualified beneficiaries who would otherwise lose their HRA coverage due to a qualifying event, even if the HRA includes a spend-down feature.

Further, employers with HRAs generally must offer COBRA continuation coverage beyond the current plan year for the maximum coverage period applicable under COBRA. If an employee elects COBRA coverage for his or her HRA, the employee is required to have access to their unused balance as well as any additional accruals provided to similarly situated employees, less any year-to-date reimbursements. COBRA compliance for HRAs (and FSAs) can be complicated.

Although employers may be comfortable applying COBRA’s rules to their group health insurance plans, the same COBRA rules may be difficult to apply to HRAs

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What is a DCAP and How Does it Work? https://primepay.com/blog/what-is-a-dcap-how-does-it-work/ Thu, 05 Mar 2020 20:16:00 +0000 https://primepay.com/blog/what-is-a-dcap-how-does-it-work/ Child care is one of the most expensive things an employee might budget for in any given year. What if there was a way to lessen the burden, on a pre-tax basis – up to $5,000?  Enter: The DCAP. What is a DCAP? Under the tax code, a dependent care assistance program (DCAP) is a […]

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Child care is one of the most expensive things an employee might budget for in any given year.

What if there was a way to lessen the burden, on a pre-tax basis – up to $5,000? 

Enter: The DCAP.

What is a DCAP?

Under the tax code, a dependent care assistance program (DCAP) is a plan allowing an employer to provide dependent care assistance benefits for their employees on a tax-free basis. They are generally referred to as DCAPs or dependent care flexible spending accounts (dependent care FSAs).

Benefits that an employee receives from his or her DCAP account are non-taxable if:

  • The expenses are for the care of one or more qualifying individuals (for example, a child under the age of 13); and
  • The employee incurs the expense in order to enable the employee (and the employee’s spouse) to be gainfully employed.

DCAP funding.

In most cases, DCAPs are funded by employees with pre-tax dollars through payroll deductions under a 125 plan. When employees incur eligible dependent care expenses, such as expenses for babysitting or child care, they can seek reimbursement from their DCAP account.

DCAPs have to comply with the requirements in Internal Revenue Code Section 129 in order to provide tax-free dependent care assistance benefits. Also, DCAPs that allow employees to make pre-tax contributions are subject to the Code Section 125 rules for cafeteria plans, including some of the rules that apply to health FSAs (excluding the uniform coverage rule).

A DCAP that reimburses employees for their dependent care expenses will rarely be subject to ERISA. So, ERISA’s requirements, including the Form 5500 reporting requirement, don’t apply to DCAPs.

DCAPs are not group health plans, which means they are not subject to requirements under many federal rules, such as: COBRA continuation coverage, the Affordable Care Act (ACA), or HIPAA. Because DCAPs are not group health plans, participating in a DCAP does not disrupt eligibility to make contributions to health savings accounts (HSAs).

How to determine if a DCAP is right for your business.

Not every employer, or employee population, however, will be able to take full advantage of a DCAP. DCAPs are subject to nondiscrimination testing (NDT) requirements and for some employers whose employees are predominantly highly compensated, or top-heavy, the program might add increased administrative burdens and minimal benefit due to a greater likelihood of NDT failures. In fact, some of the most common NDT failures relate to DCAPs. Examples of these types of businesses include legal, engineering and accounting firms as well as medical practices.

But how does a failure create an administrative burden? If a plan discovers a potential failure midyear, it can adjust employee withholdings to avoid that failure. If a failure is not discovered until after the end of the tax year, however, highly compensated employees will lose the entirety of the tax advantage of their DCA reimbursements resulting in a need to issue amended Forms W-2 to affected employees, adjusting their gross income. Not only does this create an administrative burden for employers, it can be frustrating for employees who are not able to utilize the full $5,000 limit of this benefit.

Let PrimePay help with any administrative burden associated with pre-tax health plans!

Schedule a call today

Please read our disclaimer here.

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