The reporting of an integrated HRA is required only for the participants that are not enrolled in the employer’s group medical plan and that HRA reimburses more than just dental or vision expenses.
The vast majority of HRAs only cover employees that are enrolled in the employer’s group medical plan to reimburse some or all of the out-of-pocket expenses incurred under the health plan, such as deductibles, co-insurance or copays. Those integrated HRAs need not report the HRA on Form 1095-B or Form 1095-C. IRS 1095-C instructions and 1095-B instructions can provide additional details.
Employers that provide HRAs that are not integrated with the employer’s group medical plan and reimburse more than just dental or vision expenses are required to provide the reporting to the participants in that HRA and to the IRS in early 2017 for coverage provided in 2016. Commonly, these are HRAs that cover retirees, former employees or employees that are enrolled on another employer’s group health plan (such as a spouse’s employer’s plan).
Any employer that offers an HRA that is subject to the 6055 or 6056 reporting should take steps now to gather the information necessary to produce the report in early 2017 for coverage provided in 2016.