The Tool Desk
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The Internal Revenue Service states in Publication 969 (2025): “An HRA must be funded solely by an employer.” Employee salary reductions cannot fund an HRA, and reimbursements generally must cover qualified medical expenses incurred on or after the participant’s enrollment date. The practical goal is a process that can show, for each payment, who was covered, what was purchased, when it was incurred, why the plan allowed it, what evidence supported the decision, and how the payment was recorded.
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Identify the arrangement before writing procedures
“Medical reimbursement plan” is not a precise legal category. The documentation, notices, coverage checks, tax treatment, and interaction with other benefits depend on the design. Confirm the arrangement with qualified benefits counsel or the plan administrator before relying on a generic HRA checklist.
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| Arrangement | Core characteristic | Documentation and administration focus |
|---|---|---|
| Conventional HRA | Employer-funded reimbursement of eligible medical expenses under defined plan terms. | Eligibility classes, covered expenses and people, substantiation, balances, claims and appeals, and coordination with other group benefits. |
| Individual coverage HRA (ICHRA) | Reimbursement arrangement tied to individual health insurance coverage or Medicare when the applicable conditions are met. | All ordinary expense substantiation plus annual and ongoing verification that each participant has qualifying individual coverage. |
| Qualified small employer HRA (QSEHRA) | A distinct small-employer design with its own employer eligibility conditions, coverage-proof rules, reimbursement limit, and Form W-2 reporting requirements. | Eligibility, proof of coverage, statutory annual limit, employee notices, and year-end reporting. Use the current IRS guidance for the applicable year. |
Governmental plans and most church plans generally fall outside ERISA, while private-employer plans may be covered. That status affects summary plan descriptions, claims procedures, fiduciary duties, and participant disclosures. The Department of Labor’s Plan Information page and its fiduciary-responsibilities guide explain the framework. Document the conclusion and the facts supporting it; do not assume that calling an arrangement an HRA settles the ERISA question.
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Step 1: Define the plan’s legal and operational scope
Before collecting receipts, write down the design that the administrator must apply. The following intake record prevents a common failure: an administrator processing claims without knowing which employees, expenses, dates, or other coverage rules control.
- Sponsor: legal employer name, plan name, plan number if used, and the person or committee with authority to amend or interpret the plan.
- Design: conventional HRA, ICHRA, QSEHRA, or another specifically documented arrangement.
- Eligibility classes: employee groups, waiting periods, employment status, geographic classes, and any permitted exclusions.
- Coverage dates: effective date, plan year, enrollment date for each participant, and termination rules.
- Funding: employer contribution method, allowance frequency, annual or monthly caps, and whether balances carry forward.
- Covered people: employee, spouse, dependents, or another class expressly permitted by the plan.
- Interaction with other benefits: group medical coverage, individual policies, Medicare, health savings account eligibility, cafeteria-plan elections, and coordination rules.
- Administration: claims intake channel, decision-maker, payment method, payroll contact, privacy owner, and escalation route.
Do not describe an unused balance as cash that can be paid to a participant for any purpose. The IRS warns that distributions available for nonmedical purposes can make HRA distributions taxable. If the plan allows a balance to carry forward, say that it remains available only for expenses that satisfy the plan and tax rules.
Step 2: Assemble the governing document and record set
The signed plan document is the administrator’s source of truth. A benefits summary or spreadsheet can support operations, but it should not silently replace formal terms. Keep the executed plan, amendments, approval resolutions, and the administrative agreements that explain who performs each task.
Terms the plan document should answer
- Who may participate and when eligibility starts.
- Which expenses qualify, which are excluded, and which covered persons may incur them.
- Whether an expense must be incurred after enrollment and how the plan treats expenses during a leave or after termination.
- The allowance, reimbursement cap, frequency, carry-forward rule, and any prorating for partial-year eligibility.
- Required evidence, submission deadlines, correction procedures, and the method used to request missing information.
- How claims are decided, where an appeal goes, who reviews it, and the time frames that apply.
- Coordination with other plans and any rule preventing duplicate reimbursement.
- What happens to unused amounts at plan-year end, termination, retirement, or death.
- Amendment, termination, and records-access provisions.
Records to maintain
Build a controlled file structure, whether electronic or paper, that allows an auditor, participant, or reviewer to reconstruct a decision without searching through personal inboxes.
- Signed plan document, adoption resolution, amendments, and the current plan-year version.
- Insurance or administrative-service agreements and a written allocation of responsibilities.
- Eligibility lists, enrollment and termination records, and allowance calculations.
- Participant communications, notices, summary plan description (SPD), and summaries of material modifications (SMMs) where applicable.
- Claims procedures, appeal procedures, current forms, and evidence that participants received them.
- Claim forms, receipts or other substantiation, coverage attestations, requests for more information, approvals, denials, appeal submissions, and appeal decisions.
- Payment records, balance reconciliations, payroll or tax-reporting files, and correction entries.
- Correspondence about eligibility, denials, appeals, overpayments, privacy incidents, and plan interpretation.
Use version control. A claim should be evaluated under the plan and claims procedure in force for the relevant period, with the applicable version retained alongside the decision.
Step 3: Decide whether ERISA disclosures apply
For an ERISA-covered health plan, participants need understandable written information about how the plan operates and how to obtain benefits. The Department of Labor explains SPD requirements at dol.gov/general/topic/health-plans/planinformation. The SPD should describe eligibility, funding and benefits, claims filing, review of adverse decisions, and the people or entities responsible for administration. If a material change affects those terms, provide a revised SPD or an SMM as applicable.
Maintain proof of distribution: the version delivered, delivery method, date, recipient population, and any returned or undeliverable notice. A plan that has a good document but cannot show participants received it has a practical administration problem.
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Fiduciary and service-provider oversight
ERISA fiduciaries must act prudently and in participants’ interests. A vendor performing only ministerial data entry is not automatically a fiduciary, but discretionary authority over eligibility, claims, or benefit interpretation can change the analysis. The employer remains responsible for selecting and monitoring service providers and for ensuring that the claims process works. Keep contracts, service-level reports, error logs, audit results, and evidence of periodic review.
Claims and appeals information
The plan’s claims procedure should tell a participant:
- where and how to submit a claim;
- what information and documents are required;
- who can answer questions;
- how the administrator evaluates eligibility, timing, amount, and medical purpose;
- how and when a denial is issued; and
- how to appeal, where to send the appeal, and when a decision is due.
The Department of Labor’s Employer’s Guide to Health and Disability Benefit Claims describes reasonable procedures and the requirement for a full and fair review on appeal. Preserve the procedure version and participant-distribution evidence with the plan records.
Step 4: Build a substantiation workflow that works claim by claim
A reimbursement is not approved merely because an employee swiped a card or described an expense as “medical.” The administrator must connect the expense to the participant, a covered person, an eligible date, an eligible service or product, and the amount payable under the plan.
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- Verify identity and coverage. Confirm the participant’s identity, eligible class, enrollment date, covered person, and coverage status for the date of service or purchase.
- Check timing. Confirm that the expense was incurred on or after the participant entered the HRA and falls within the relevant plan-year or submission window.
- Inspect evidence. Review the provider or merchant, service or product description, date, amount, and proof of payment when the plan requires it. Redact unrelated sensitive information while retaining enough to decide the claim.
- Apply plan rules. Match the expense to the plan’s eligible categories, exclusions, reimbursement limit, remaining balance, and coordination provisions. For an ICHRA, complete the separate qualifying-coverage check.
- Resolve deficiencies. Request the specific missing item and give a reasonable response route. If the evidence cannot establish eligibility, issue a plan-based denial explaining the appeal path.
- Approve and pay. Authorize only the supported amount, use the permitted payment method, and record the payment date, amount, and recipient.
- Reconcile and close. Update the participant’s remaining allowance, reconcile the claim register to the bank or payroll file, and store the decision and communications together.
Separate claim approval from payment release when practical. A second review for unusual amounts, manual overrides, related-party expenses, or repeated corrections reduces the risk that an entry error becomes a tax or fiduciary problem.
What employees should submit for reimbursement
Tell participants exactly what evidence is needed. A generic instruction to “send a receipt” is inadequate because many receipts omit the covered person, service date, or proof that the employee actually paid.
| Required fact | Acceptable evidence examples | Administrator’s test |
|---|---|---|
| Participant and covered person | Claim form, member record, or provider statement identifying the patient. | Is the person eligible under the plan? |
| Date incurred | Itemized bill, explanation of benefits, pharmacy record, or provider receipt showing service or purchase date. | Did the expense occur during an eligible period? |
| Description | Itemized invoice, procedure description, prescription record, or merchant detail. | Can the reviewer determine that the expense fits an allowed category? |
| Amount | Invoice, receipt, explanation of benefits, or other itemized statement. | What amount is eligible after discounts, insurance, or other reimbursements? |
| Payment | Paid receipt, card statement, cancelled check, or other proof when required by the plan. | Was the expense actually paid or otherwise incurred by the participant or covered person? |
| Coverage, for an ICHRA | Required attestation or third-party coverage evidence under the applicable process. | Did qualifying individual coverage exist for the required period? |
Do not demand more medical information than the plan needs to decide eligibility. A diagnosis is often unnecessary; an itemized description and date may be enough. Restrict access to protected health information, use role-based permissions, and avoid sending full medical records through unencrypted email.
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Payment cards do not replace substantiation
IRS Publication 969 permits debit, credit, or stored-value cards for HRA payments, but a card transaction avoids additional participant documentation only when an accepted substantiation method applies. A merchant category code or a card swipe, by itself, does not prove that a purchase was an eligible medical expense. Build automated substantiation rules only for transaction types that the plan and applicable IRS guidance permit; route ambiguous transactions for documentation or manual review.
Special administration for an ICHRA
An ICHRA adds a coverage-verification obligation to ordinary expense substantiation. It may be integrated with individual health insurance coverage or Medicare only when the applicable conditions are satisfied. The IRS summarizes the ACA tax provisions at irs.gov/affordable-care-act/affordable-care-act-tax-provisions.
Coverage workflow
- At enrollment, identify the individual policy or Medicare coverage that satisfies the ICHRA condition.
- Collect the required annual attestation or third-party evidence using the current process.
- Before paying a claim, confirm that qualifying coverage was in force for the relevant period.
- Run ongoing verification when coverage changes, a participant reports termination, or the plan’s procedure requires periodic confirmation.
- Pause or deny reimbursement when coverage cannot be established, explain the deficiency, and provide the correction or appeal route.
The Department of Labor publishes Individual Coverage HRA Model Attestations. Use the current official model forms and regulation rather than adapting a conventional-HRA receipt checklist. Store the attestation, verification date, evidence source, and any follow-up with the participant’s coverage record.
Keep QSEHRA administration separate
A QSEHRA is not simply a conventional HRA with a smaller allowance. Employer eligibility conditions, proof-of-coverage requirements, a statutory reimbursement limit, participant notices, and Form W-2 reporting apply. Annual limits and reporting instructions can change. The 2026 Publication 15-B material surfaced in unofficial copies, so verify the current-year dollar amount and instructions directly in the current IRS publication before setting allowances or preparing payroll files. Do not copy a prior year’s limit into a new plan document without checking the current rule.
Maintain a QSEHRA checklist that ties each participant’s reimbursement to coverage proof, the applicable annual limit, notice delivery, and year-end reporting. If an employee has other minimum essential coverage or changes coverage during the year, route the event through the plan’s documented eligibility and notice process.
Record retention: create a schedule without inventing a universal period
The governing materials establish substantiation and disclosure duties, but they do not establish one retention period that applies to every HRA claim, plan document, tax record, and privacy-sensitive file. The correct period can depend on the record category, federal and state law, plan terms, audit exposure, privacy obligations, and a litigation hold.
Adopt a written schedule after checking current requirements with qualified counsel or the plan administrator. Classify records instead of assigning one number to everything: plan documents and amendments, participant notices, eligibility data, claims and substantiation, payment and payroll records, tax reports, appeals, vendor oversight, and privacy incidents. State when the clock starts, who owns the record, where it is stored, and what overrides routine deletion. Suspend destruction when a dispute, audit, government inquiry, or litigation hold requires preservation.
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Controls for privacy, accuracy, and reconciliation
- Role-based access: Give eligibility staff, claims reviewers, payroll staff, and auditors only the fields they need.
- Change logs: Record edits to eligibility, allowances, claim decisions, and payment details with user, timestamp, old value, and new value.
- Duplicate-payment checks: Match claim number, participant, covered person, provider, date, and amount before releasing a second payment.
- Balance reconciliation: Reconcile approved claims and reversals to the plan ledger, bank account, and payroll or tax file at a defined interval.
- Exception reports: Review manual overrides, claims paid without normal evidence, negative balances, expired coverage, and repeated resubmissions.
- Business continuity: Maintain recoverable backups and a documented process for accepting claims if a portal or administrator is unavailable.
- Vendor review: Check security controls, breach-notification terms, subcontractors, data-return obligations, insurance, service levels, and the vendor’s exercise of discretion.
Choosing an administrator or operating the plan internally
Compare administration methods on the work they must perform, not on a generic “benefits platform” label. An internal process may offer direct control but requires staff, secure storage, review expertise, and continuity coverage. A third-party administrator may automate intake and balances but does not transfer the employer’s responsibility to select, monitor, and correct the service.
| Decision axis | Questions to document |
|---|---|
| Eligibility | Can the system apply employee classes, waiting periods, effective dates, leaves, and terminations without manual workarounds? |
| Expense rules | Can it enforce covered expense categories, covered persons, caps, carry-forward, and coordination rules? |
| ICHRA verification | Does it support annual and ongoing coverage attestations or approved third-party evidence? |
| Claims and appeals | Can participants submit, receive a reasoned decision, appeal, and track deadlines and outcomes? |
| Payroll and benefits integration | Can allowances, payments, reversals, and year-end reporting reconcile to authoritative payroll and enrollment records? |
| Privacy and access | Are permissions, audit logs, encryption, retention, exports, and breach procedures documented? |
| Discretion and oversight | Who decides eligibility or benefit interpretation, and how does the employer review that discretion? |
| Participant support | Can employees obtain forms, status updates, missing-document requests, and appeal instructions in an accessible way? |
Put service responsibilities in writing. The contract should identify who owns data, who issues notices, who handles appeals, who corrects an erroneous payment, and how records are returned or securely destroyed at termination.
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Common failure modes and fixes
Using one checklist for every HRA
Symptom: The same receipt and coverage process is used for a conventional HRA, ICHRA, and QSEHRA.
Fix: Maintain design-specific procedures and a decision record identifying which rules apply before enrollment opens.
Approving claims with no service date
Symptom: A receipt shows only a statement date or card-posting date.
Fix: Request the date the service or purchase was incurred, then test it against enrollment and plan-year rules.
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Symptom: Every card transaction is paid automatically.
Fix: Apply only permitted substantiation methods and send ambiguous transactions for evidence or manual review.
Missing participant disclosures
Symptom: The employer has a plan document but no distribution log, current SPD, or SMM.
Fix: Version the disclosure, document delivery, and update it when a material change occurs.
Unclear denials and appeals
Symptom: A denial says “not covered” without identifying the missing evidence or appeal route.
Fix: Tie the decision to the plan provision, state what information was considered, explain what can cure the deficiency, and provide the applicable appeal instructions and deadline.
Overbroad retention or deletion
Symptom: All files are deleted after one arbitrary period, or sensitive medical data is retained indefinitely.
Fix: Use a category-based schedule, apply legal holds, limit access, and obtain current legal and privacy advice.
Operational calendar for a well-run plan
- Before the plan year: confirm design, ERISA analysis, eligibility classes, allowance limits, plan document, claims procedure, forms, privacy controls, and administrator responsibilities.
- At enrollment: capture effective dates, covered people, required elections or attestations, and delivery of participant materials.
- Every claim: verify identity, timing, expense, amount, coverage where required, decision, payment, and balance.
- Monthly or at another defined interval: reconcile the claim ledger, bank or payroll file, allowance balances, and exception report.
- When the plan changes: approve the amendment, determine participant notice obligations, update procedures, and preserve both prior and current versions.
- At termination or year-end: apply the documented carry-forward and submission rules, stop or adjust allowances, handle outstanding appeals, and complete required reporting.
- Periodically: review vendors, access rights, security controls, denial patterns, correction rates, and whether the written procedure matches actual practice.
A defensible administration file is one in which the plan terms, participant communication, evidence, decision, payment, and review history agree. If a reviewer cannot follow that chain for a single claim, improve the process before adding more automation.
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