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HRA types & plan design

Types of HRA: ICHRA, QSEHRA and other arrangements

Different HRAs solve different benefits problems. Use this guide to identify the arrangement before applying rules about insurance, contributions or reimbursement.

The short answer

Common HRA designs include ICHRA, QSEHRA, group-integrated HRAs and excepted benefit HRAs. They share employer-funded reimbursement, but they do not share one eligibility test, contribution limit or list of permitted premiums. HSA and health FSA are separate benefits. source source source

What are the main types of HRA?

ArrangementTypical purposeKey boundary
ICHRAReimburse qualifying individual health insurance or Medicare premiums and, if included, other eligible expenses.Employers of any size; covered people need qualifying individual coverage or Medicare. Permitted employee-class rules apply.
QSEHRAHelp eligible small employers reimburse employee health expenses.Employer must not be an applicable large employer and must not offer a group health plan to current employees. Annual statutory limits apply.
Group-integrated HRASupplement group health coverage, such as by reimbursing certain deductibles.The HRA and group coverage must satisfy integration rules; it is not a substitute for individual-premium reimbursement under ICHRA.
Excepted benefit HRAProvide a limited additional reimbursement benefit.Traditional group coverage must be offered, though enrollment is not required. An indexed annual limit and restrictions on reimbursable premiums apply.

This is an orientation table, not an exhaustive catalog of every permitted HRA design. Each arrangement needs compliant plan documents. source source

When would an employer compare ICHRA and QSEHRA?

Compare these when the intended benefit is reimbursement toward employees' own coverage. ICHRA is available to employers of any size and has no federal annual contribution cap. QSEHRA is limited to eligible small employers and has an indexed annual reimbursement ceiling. Both require more than simply adding a health allowance to payroll. source source

Their treatment of group coverage and Marketplace tax credits differs. A QSEHRA employer cannot retain a group health plan for one class of current employees and give QSEHRA to another. ICHRA can coexist with a group plan for separate permitted classes under specific conditions. Use the full ICHRA–QSEHRA comparison before choosing.

Can an HRA work alongside a group health plan?

Yes. A group-integrated HRA can help with expenses under group coverage, such as an employee's deductible. The employer must satisfy the applicable integration requirements, including coverage enrollment conditions. The HRA documents determine which expenses qualify and how much can be reimbursed. source

For example, an employer might keep its group insurance and reimburse part of an employee's eligible deductible costs. That is a different design from reimbursing an individual policy through ICHRA. Neither the insurer nor its network is replaced merely because an HRA pays part of the cost. If your objective is to replace a group policy, read ICHRA versus group insurance.

What makes an excepted benefit HRA different?

An excepted benefit HRA is a limited supplemental benefit. The employer must offer traditional group coverage to the employees offered the HRA, but they do not have to enroll in that group coverage to participate in the excepted benefit HRA. It must be offered on the same terms to similarly situated individuals, regardless of health factors. source

It cannot reimburse individual major-medical, ordinary group-health or Medicare premiums; COBRA or other group continuation premiums are an exception to the group-premium restriction. Other permitted reimbursements depend on the plan. Its indexed limit is separate from QSEHRA limits and from ICHRA's lack of a federal contribution cap. An excepted benefit HRA alone is not comprehensive insurance or minimum essential coverage. source

Are retiree-only and limited-purpose HRAs different categories?

These labels describe additional design features or populations, so they should not be treated as interchangeable alternatives in one simple ranking. A retiree-only arrangement addresses former employees. A limited-purpose or post-deductible HRA restricts reimbursement in ways that can matter for HSA contribution eligibility. The actual terms determine how the rules apply. source source

Ask for the formal arrangement name, who can participate, the coverage requirement and the expense list. “Health wallet,” “HRA account” or a debit card brand is not enough to identify the legal structure.

What should an employer establish before selecting an HRA?

  1. Whether existing group coverage will continue, end or remain for permitted classes.
  2. The employer's size and applicable-large-employer status, including relevant related employers.
  3. What coverage employees currently have and whether it qualifies for the proposed arrangement.
  4. The reimbursement budget, eligible expenses and employee tax-credit implications.
  5. Who will prepare documents, send notices, substantiate claims and help employees.

These questions identify the right next analysis; they do not automatically establish that a design is compliant or cheaper. Keep premium costs separate from administrator service fees.

Where to go next

Sources and evidence

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