The Essentials of HSA, HRA, and FSA
HSAs, FSAs, and HRAs are three very common types of health plan arrangements that employers offer to their employees. These plans are important considerations for employers when determining what type of health insurance to offer employees. Each type of plan has its own set of unique regulations that employers must navigate when administering them. The important rules and distinctions for each plan are below:
- Who Can Contribute?
o HSA: Employer and eligible employees (pre-tax or post-tax)
o HRA: Employer only
o FSA: Employer and employee (pre-tax only)
- What Are the Contribution Limits for the Plan?
Maximum Contributions for 2022:
• Single: $3,650
• Family: $7,300
o HRA: The Contribution amount is defined by the employer.
o FSA: $2,850 maximum (adjusted annually). However, an employer may set a lower contribution limit for their particular plan. Employers may also make contributions above this limit (up to $500 to avoid most federal obligations related to employer contributions).
- What Medical Expenses are Covered Under the Plan?
All §213 medical expenses (including over-the counter drugs and menstrual products) and long-term care expenses (including premiums), but not health insurance premiums
Certain premiums (COBRA and qualified long-term care coverage; health plan coverage while receiving unemployment compensation; health plan coverage (other than Medicare supplemental insurance) for those age 65 or older)
All §213 medical expenses (including over-the counter drugs and menstrual products);
Certain premiums, if under a Retiree HRA, qualified small employer health reimbursement arrangement, or individual coverage HRA;
LTC expenses and LTC premiums
All §213 medical expenses (including over-the counter drugs and menstrual products) except long- term care expenses and insurance premiums
- When are Plan Funds Made Available?
o HSA: Funds become available as contributions are made to the account
o HRA: Funds are available on the first day of the plan year
o FSA: Funds are available on the first day of the plan year
- Does the Arrangement Allow Coverage Under Another Health Plan?
o HSA: Yes, if it is an HDHP
o HRA: Yes
o FSA: Yes
- Which Individuals are Eligible for Reimbursement?
o HSA: HSA holder, spouse, and tax dependents
o HRA: Participating employee/former employee, spouse, eligible children to end of calendar year turning age 26 and tax dependents
o FSA: FSA account holder, spouse, eligible children to end of calendar year turning age 26 and tax dependents
- Are Plan Documents Required?
o HSA: Usually, no (however, plan documents of the HDHP are still required)
o HRA: Yes. If the plan has over 100 participants, a Form 5500 is also required to be filed.
o FSA: Yes. If the plan has over 100 participants, a Form 5500 is also required to be filed.
- What Are the Plan Design Restrictions?
o HSA: An HSA must be connected to a High Deductible Health Plan (HDHP). This requires a plan with a minimum deductible (for 2022) of $1,400 (single)/$2,800 (family). In addition, the plan must have a 2022 maximum out of pocket of $7,050 (single)/$14,100 (family).
o HRA: The plan participant must either (1) be enrolled with a group medical plan (including the plan of another employer) or (2) only be a spend down account or only reimburse dental or vision expenses
o FSA: The employer must provide Uniform Coverage, a 12-month plan year, and one of the following restrictions on employees:
The employee must forfeit all unused funds at the end of each plan year (except for a carryover balance up to $570 (adjusted annually); or
The employee must forfeit all unused funds at the end of 2 ½ months after each plan year (no carryover).