Health Reimbursement Account Implementation Checklist

Advise clients on best practices to use when establishing a compliant employer-sponsored health reimbursement account (HRA) benefit plan with this checklist from Troutman Pepper LLP partners Emily D. Zimmer and Lynne S. Wakefield. Review federal law requirements on HRAs, including applicable provisions of the Patient Protection and Affordable Care Act (ACA), the Employee Retirement Income Security Act (ERISA), the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA), the Health Insurance Portability and Accountability Act (HIPAA), and the Internal Revenue Code (IRC).

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Related Content

• Health Reimbursement Account Design and Compliance
  Rely on this practice note, also from Troutman Pepper LLP partners Emily D. Zimmer and Lynne S. Wakefield, to get up to speed on the design and operation of employer-sponsored HRAs. Address compliance considerations under the IRC, ERISA, COBRA, HIPAA, and, particularly, the ACA. Also learn about new rules allowing employers to offer so-called individual coverage HRAs (ICHRAs) and excepted benefit HRAs (EBHRAs).
• Health Savings Account Design and Compliance
  Counsel clients on the requirements for establishing and maintaining health savings accounts (HSAs), which allow individuals covered by high-deductible health plans (HDHPs) to receive tax-preferred treatment of their contributions, with this practice note from Baker & Hostetler LLP partner Brian M. Murray. Differentiate between types of medical expenses—like deductibles and out-of-pocket medical expenses—that can and cannot be paid from HSAs.
• Claims Procedure ERISA Requirements Checklist (Group Health Plans)
  Use this checklist to verify that your clients’ benefit claims procedures comply with both ERISA and the ACA. Develop processes to ensure your clients’ programs establish and maintain protocols reasonably designed to ensure a full and fair review of benefit claims and claimant appeals of adverse determinations.

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