September 22, 2015

Filing requirements for HRAs have been fixed!

NAHU_Logo_ColorNAHU is happy to share with you that the 2015 1094-B and 1095-B filing requirements for HRAs have been fixed! In early August, the IRS released draft instructions for 1094-B and 1095-B that included HRA filing requirements. NAHU reached out to the Administration regarding the affect this would have on employers, and last week the final instructions were released and language requiring HRA filings has been changed.

The final instructions now provide that an employer with a fully insured major medical plan and HRA coverage, for which the individual is eligible because they are enrolled in the employer group major medical plan, does not have to report the HRA on Form 1095-B. Specifically, the revised instructions now state:

An employer with an insured major medical plan and HRA coverage for which an individual is eligible because the individual enrolls in the insured major medical plan is not required to report the coverage under the HRA for an individual covered by both arrangements.

There are some exceptions; most noteworthy is if an individual is covered by an HRA sponsored by one employer and a non-HRA group health plan sponsored by another employer (such as spousal coverage). In this situation each employer must report the coverage the employer provides.

NAHU is pleased with the action taken by the IRS, and will continue to advocate with Congress for the streamlining of employer reporting.