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HRAs Off the Hook for Annual Waiver Limits

by on
in Compensation and Benefits,Human Resources

For plan years beginning Sept. 23, 2011, unless the U.S. Department of Health and Human Services grants a waiver, group health plans that impose annual or lifetime limits on the dollar value of essential benefits are restricted to imposing an annual limit of $1.25 million.

Break: For plan years beginning before 2014, when waivers will no longer be available, stand-alone health reimbursement accounts (HRAs), which were in effect prior to Sept. 23, 2010, have received a blanket exemption from the annual waiver application process.

Warning: HRAs must still comply with the record retention requirement and annually notify employees that they can continue to impose limits on essential benefits. Model language is available at http://tinyurl.com/6y79qmg.

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