Health Reimbursement Arrangements

Health reimbursement arrangements (HRAs) are a type of account-based health plan that employers can use to reimburse employees for their medical care expenses. 

New rules released by the Departments of Labor, Health and Human Services, and the Treasury permit employers to offer a new “individual coverage HRA” as an alternative to traditional group health plan coverage, subject to certain conditions.  Among other medical care expenses, individual coverage HRAs can be used to reimburse premiums for individual health insurance chosen by the employee, promoting employee and employer flexibility, while also maintaining the same tax-favored status for employer contributions towards a traditional group health plan.      

The new rules also increase flexibility in employer-sponsored insurance by creating another, limited kind of HRA that can be offered in addition to a traditional group health plan.  These “excepted benefit HRAs” permit employers to finance additional medical care (for example to help cover the cost of copays, deductibles, or other expenses not covered by the primary plan) even if the employee declines enrollment in the traditional group health plan.  

Additional Resources

• Individual Coverage Health Reimbursement Arrangements: Policy and Application Overview (PDF)
• Overview of New Health Reimbursement Arrangements Part One Slides (PDF)
  • Overview of New Health Reimbursement Arrangements Part One Slides – Spanish (PDF)
• Overview of New Health Reimbursement Arrangements Part Two Slides (PDF)
  • Overview of New Health Reimbursement Arrangements Part Two Slides – Spanish (PDF)
• Individual Coverage HRAs and Qualified Small Employer HRAs: Issuer Requirements Overview (PDF)
• 2020 CMS Healthcare Innovation Industry Day Slides (PDF)
• Health Reimbursement Arrangements and Other Account-Based Group Health Plans Proposed Rule (PDF) 
• Health Reimbursement Arrangements and Other Account-Based Group Health Plans Final Rule (PDF)
• Individual Coverage HRA Model Attestations (DOCX)
  Individual Coverage HRA Model Attestations  (PDF)
• Individual Coverage HRA Model Notice (DOCX)
  Individual Coverage HRA Model Notice (PDF)
• Frequently Asked Questions (PDF)  
• Procedural Guidance for States to Recommend Restricting Certain Excepted Benefit Health Reimbursement Arrangements from Reimbursing Premiums for Short-term, Limited-duration Insurance (PDF) 

ICHRA Employer LCSP Premium Look-up Table

To help employers determine whether an ICHRA offer is considered affordable for purposes of validating they are making affordable offers of coverage to their employees and avoiding the employer responsibility payment, CMS is publishing the ICHRA Employer LCSP Premium Look-up Table. The table allows users in states participating in the Federally-facilitated Exchange (FFEs) and State-based Exchanges on the Federal Platform (SBE-FPs) to access individual market Qualified Health Plans (QHP) lowest cost silver plan (LCSP) data by geographic location.

For additional information, please review the ICHRA Employer LCSP Premium Look-Up Table and the associated ICHRA Employer LCSP Premium Look-up Table Data Dictionary, as well as the proposed rule. "Application of the Employer Shared Responsibility Provisions and Certain Nondiscrimination Rules to Health Reimbursement Arrangements and Other Account-Based Group Health Plans Integrated With Individual Health Insurance Coverage or Medicare"

Plan Year 2019

ICHRA Employer Lowest Cost Silver Plan Premium Lookup Table (VND.MS-EXCEL.SHEET.MACROENABLED.12)
ICHRA Employer Lowest Cost Silver Plan Premium Look-up Table Data Dictionary (PDF)

Plan Year 2020

ICHRA Employer Lowest Cost Silver Plan Premium Look-up Table (VND.MS-EXCEL.SHEET.MACROENABLED.12)
ICHRA Employer Lowest Cost Silver Plan Premium Look-up Table Data Dictionary (PDF)

Plan Year 2021

ICHRA Employer Lowest Cost Silver Plan Premium Look-up Table (VND.MS-EXCEL.SHEET.MACROENABLED.12) (XLSM)
ICHRA Employer Lowest Cost Silver Plan Premium Look-up Table Data Dictionary (PDF)

Plan Year 2022

ICHRA Employer Lowest Cost Silver Plan Premium Look-up Table (VND.MS-EXCEL.SHEET.MACROENABLED.12) (XLSM)
ICHRA Employer Lowest Cost Silver Plan Premium Look-up Table Data Dictionary (DOCX)

Plan Year 2023

ICHRA Employer Lowest Cost Silver Plan Premium Look-up Table (VND.MS-EXCELSHEET.MACROENABLED.12) (XLSM)
ICHRA Employer Lowest Cost Silver Plan Premium Look-up Table Data Dictionary (PDF)

Plan Year 2024

ICHRA Employer Lowest Cost Silver Plan Premium Look-up Table (VND.MS-EXCELSHEET.MACROENABLED.12) (XLSM)
ICHRA Employer Lowest Cost Silver Plan Premium Look-up Table Data Dictionary (PDF)

Employee 3-step Guide

Employees with an HRA notice from their employer can answer a few questions on HealthCare.gov to get a 3-step guide based on their situation.