NO.
How to Have an HRA and HSA Simultaneously
As noted, to open and contribute to an HSA, participants must be enrolled in a qualified HDHP, and have no other health coverage. The HRA must be integrated with a group health plan. With those two conditions met, four HRA plan types are compatible with an HSA, per IRS regulations.
The Four HRA Types that are HSA-Compatible
- Limited Purpose HRA: Pays or reimburses only permitted healthcare coverage (including vision and dental), permitted insurance, or preventative care. These expenses do not count toward the HDHP deductible.
- Post-deductible HRA: Pays for or only reimburses preventative care or medical expenses incurred after meeting the minimum annual HDHP deductible.
- Retirement HRA: Covers eligible expenses only after retirement. Before retirement, the participant uses an HSA to cover the expenses. Once HSA eligibility is lost after retirement, the participant switches to the HRA.
- Suspended HRA: The participant suspends an HRA by electing to forego reimbursement/payment for medical expenses incurred during the coverage period. This must be done before HRA coverage begins. During the suspension, the person is HSA-eligible. The suspension does not apply to expenses that are permitted insurance, permitted coverage, or preventive care.
Consult IRS Ruling 2004-45 for further guidance.
