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Health Reimbursement and HSA

Can you have a post deductible HRA and contribute to an HSA at the same time while enrolled in a HDHP? 

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5 Replies

Health Reimbursement and HSA

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

  1. 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.
  2. Post-deductible HRA: Pays for or only reimburses preventative care or medical expenses incurred after meeting the minimum annual HDHP deductible.
  3. 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.
  4. 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.

Health Reimbursement and HSA

The key phrase I'm looking at is "medical expenses incurred after meeting the minimum annual HDHP deductible". Isn't that a guideline that is set every year? For 2024 the minimum annual deductible for a HDHP was $3,200 for a family. The IRS website says these deductibles for the HRA and HDHP DO NOT have to be the same as long as they meet the minimum annual deductible.

Health Reimbursement and HSA

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Health Reimbursement and HSA

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DaveF1006
Employee Tax Expert

Health Reimbursement and HSA

It depends. it is correct that the HDHP and HRA deductibles are not the same. A HRA plan pays for some health care expenses that are not paid for in a high deductible health plan thus making health care costs more manageable.

 

In an HRA, the deductible is $3200 for a family which is the minimum amount a family must pay out of pocket before the HRA starts reimbursing qualified medical expenses. A family uses their HRA to reimburse for medical expenses that are not normally covered by a high deductible health plan.

 

 

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