ACA Reporting Part II – Do I need to report HRA benefits?

Health Reimbursement Arrangements (HRAs) are generally considered “minimum essential coverage” for which reporting is required under the new Affordable Care Act (ACA) reporting due the first quarter of 2016. However, certain HRAs are exempt from reporting under the most recent instructions for the reporting forms. There are two sets of reporting forms: The reporting forms for Section 6055 are the “B” forms (1094-B and 1095-B) and the reporting forms for Section 6056 are the “C” forms (1094-C and 1095-C).

The Issue with HRAs is whether the employer must report the employees who are enrolled in its HRA in addition to the employees enrolled in the group health plan. Below are some helpful clarifications on reporting requirements:

If I offer a fully-insured group health plan and an HRA to only my employees who are enrolled in the group health plan, what are my reporting requirements?

The insurer (health carrier) is obligated to report under 6055 with respect to your fully-insured group health plan. If you are a small employer (under 50 full-time employees and full-time employee equivalents) you have NO obligation to report the HRA nor do you have any further obligation to report. If you are a large employer (with 50 or more full-time employees and full-time employee equivalents) you have NO obligation to report the HRA coverage but you are still required to complete the 6056 reporting (1094-C and the 1095-C). Since the HRA is not reported separately you will leave part III of the 1095-C blank.

If I offer a self-funded group health plan and an HRA to only my employees who are enrolled in the group health plan, what are my reporting requirements?

You do not need to separately report the HRA (because it is bundled with the primary self-funded coverage). If you are a small employer you are required to report the employees enrolled in the primary self-funded group health plan under 6055 (the 1094-B and 1095-B), but you are not required to report under 6056. If you are a large employer you are required to report under 6056 (the 1094-C and 1095-C) and you will complete part III of the 1095-C regarding the employees enrolled in the primary self-funded group health plan.

If I offer an HRA to employees who waive my group health coverage and who enroll in group health coverage through another employer (such as a spouse’s employer), what are my reporting requirements?

In this situation you must report the employees who are enrolled in the HRA. There is no exemption. If you are a small employer you will report the employees enrolled in the HRA under 6055 (the 1094-B and 1094-B). If you are a large employer you will report the employees enrolled in the HRA under 6056 (specifically, part III of the 1095-C).

If I offer an HRA to retirees, what are my reporting requirements?

For a retiree HRA that is provided to retirees who are eligible for Medicare (e.g., age 65 or older), the HRA is considered to be a supplement to Medicare and as a result, you are not required to report the retiree HRA under 6055 or 6056.

For a retiree HRA that is provided to retirees who are not yet eligible for Medicare, reporting is required. If you are a small employer, you will report the retirees enrolled in the HRA under 6055(the 1094-B and 1095-B). If you are a large employer, in the year the employee retires you will report the retiree HRA coverage under 6056 (part III of the 1095-C). For the year(s) after the employee retires, a large employer has the option to report the retiree coverage either under 6055(the 1094-B and 1095-B) or under 6056.

If I offer an HRA which only reimburses uninsured dental and/or vision expenses, what are my reporting requirements?

Good news for you. Dental/vision only HRAs are not subject to reporting under 6055 and 6056.

What data is available from NEO’s HRA Administration platform to help with filing requirements?

The best source of data for HRA is the member detail report which is available on demand from the Employer Portal.
We only have the dependent data that has been provided or added for claim purposes. The data may not be up to date if we are not notified of changes.

Don’t go it Alone!

The rules governing ACA compliance are complicated and will continue to see additional modifications. Given the complexity of ACA compliance and the potential cost for missing the mark, it is wise to seek professional guidance. Consult with your payroll, benefits and tax professionals for more information about the law or for assistance with filing Forms 1094-B, 1095-B, 1094-C and 1095-C.

For more information on the ACA and HRA requirements: