Health Reimbursement Agreement (HRA) Employer Application External Talking Points
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1 Health Reimbursement Agreement (HRA) Employer Application External Talking Points In order to ensure a smooth implementation, we will need to obtain employer information, plan information and other criteria. The Employer Application Talking Points will assist you in the preparation of the information required for the HRA implementation. The items listed will be discussed in more detail during the initial conference call. After the initial conference call, you will receive, via , a detailed confirmation page of the information discussed to ensure the accuracy of the Plan Design. Employer Information When initially implementing an employer in our HRA system, we request specific information about the employer. Contact Information: The Plan Administrator will be the main contact for any HRA Administration questions, have access to the Aetna HRA website, receive reimbursement reports and receive the monthly administration invoice via . Plan Administrator Contact Information: Name, address, phone and fax number. If there is a different contact to receive the monthly administration invoice, we will need their name, address, phone and fax number. Organization Type: Corporation Sub Chapter S Corporation Partnership LLC Limited Liability Company Government Agency Professional Corporation Professional Association Standard Industry Code: The Standard Industrial Classification (SIC) is a classification system used in the United States to collect statistical information based on business activities. We will ask you to provide the employer s four digit SIC, or industry type. For example, a car dealership s industry is Motor Vehicle Dealer and their SIC is State Law: Some companies might have multiple locations in different states. In this case, we would need to know which state law applies to the company s plan. Participation: HRAs are not allowed to discriminate in terms of who can participate in the plan. IRS Regulations stipulate that only employees and former employees can participate in an HRA. The following are not eligible to participate in the HRA: More than 2% shareholders in an S-Corp, including employee spouses, parents, children & grandchildren Sole proprietors Partners in a partnership Members of an LLC Outside directors Anyone deemed to be Self-Employed There are some classifications allowed for employees: Full Time vs. Part Time Active vs. Former Nonunion vs. Union Ineligible Classifications: Management vs. Nonmanagement Only employees with x number of years in service Only employees with compensation in excess of x amount Eligibility Requirements HRA plan s eligibility requirements and employee participation: 1. The following class of employees are eligible to participate: All full-time employees All employees Salaried employees only Hourly employees only 1
2 2. The following employees are excluded from participation: No exclusions Part-time employees normally expected to work less than a specific number of hours a week s under a specific age Union employees (unless the bargaining agreement provides for coverage) Non-resident aliens 3. The service period employees must complete before being eligible to participate is as follows: A. For the initial plan year, anyone employed on the plan effective date and subsequent plan years: As of date of hire Number of days after date of hire Number of months after date of hire B. For all plan years: As of date of hire Number of days after date of hire Number of months after date of hire 4. Once the employees are eligible, they can begin participating in the plan: Date employee First day of pay period following the date employee First day of month following the date employee First day of quarter following the date employee First day of plan year following the date employee Plan Periods and Renewal Dates coincide with your medical policy period or can be effective based on a calendar year in order to coincide with your medical deductible. If the medical deductible runs on a calendar year, we recommend implementing the HRA on a calendar year to coincide with your deductible. When the medical deductible resets in January, so will the HRA benefit. If your HRA effective date is based on the medical plan year and your medical deductible resets based on the calendar year, there may be an impact to your employees. For example, if your medical plan is effective and the HRA is effective through , there is potential for a participant to be reimbursed the maximum HRA benefit for dates of service through If that participant has additional eligible deductible claims beginning , there are no additional HRA funds available throughout the remainder of the HRA plan. New HRA funds would not become available until after the HRA renewal for dates of service beginning Having the HRA coincide with the medical deductible eliminates this potential gap in HRA benefits. When the HRA plan is calendar year and the medical plan is non-calendar year, changes in the medical plan may result in a desired change in the HRA which would not be available until the HRA renewal. HRA plan design changes are only available at the HRA plan renewal date. Plan Designs Listed below are sample plan designs and amounts for the HRA. has responsibility prior to the HRA benefit. 1 st Tier 2 nd Tier HRA TOTAL $1, $2, $2, $3, $5, Plan Designs continue on next page. The effective date of the HRA is very important. The HRA can be effective based on the medical plan year in order to 2
3 HRA is first dollar benefit with employee responsibility second 1 st Tier HRA 2 nd Tier TOTAL Fully funded HRA, stand alone HRA or limited scope (for example, dental, vision only) 1 st Tier HRA Total Allowed Expenses $1, $2, $2, $3, $5, Listed below are the options for the eligible expenses for an HRA Plan. All 213d expenses (very similar to an FSA) This is the broadest category of reimbursable expenses and generally allows for the HRA to reimburse for any expense incurred to treat a specific medical condition, which can include over-the-counter medication, alternative therapy, dental, vision, etc. Expenses applied to the health plan deductible only Under this option, the HRA reimburses all deductible expenses, both in and out of network, Medical and Rx (if applicable) according to the plan design. Health plan related expenses Under this option, the HRA reimburses expenses incurred by the member which apply toward their underlying medical plan s deductible, coinsurance and copays, but excludes non-health related expenses, such as over-thecounter medication, dental and vision. Stand Alone or Limited Scope HRA Under this option, an HRA can be designed for just dental expenses, for example. This option provides reimbursement for dental and vision expenses. This design is utilized when the employer offers an HSA to employees. It can also be an HRA not linked to a specific medical plan. Rollover A fundamental aspect of HRAs is to allow for rollover of unused funds at the end of the plan year. The rollover applies unused funds from the previous plan year to be utilized in future plan years. For example, once the current plan year HRA benefits have been utilized, the rollover funds can be applied to any remaining employee responsibility in the current plan year. Also, by allowing employees to rollover unused funds, they have an incentive to save their funds for future eligible expenses. Spend-Down Spend-Down allows an ex-employee to submit claims for dates of service after their termination date to spend down the unused portion of their HRA account. This is not related to COBRA continuation. Streamline and Claim Submission Streamline provides the capability for automatic, paperless submission of HRA claims submitted and processed through Aetna s medical plan. Once a participant s claim is processed through medical or dental (if applicable), the claim data is provided electronically for submission through the HRA plan. The participant just has to provide their medical ID card at the time of service, and there is no need for manually submitting an Explanation of Benefit (EOB) or reimbursement form. The streamline data is received weekly and reimbursement is in accordance to our reimbursement schedule. Claims received by the 5th are reimbursed on the 15th. Claims received by the 20th are reimbursed on the last day of the month. Once a claim is processed through medical, the claim data is received within approximately 10 business days. Reimbursements for medical claims are based on when the provider submits the claim and the time required for adjudicating the claim. In most cases, the participant will receive their reimbursement for the medical claim prior 3
4 to receiving a bill from the provider. For prescriptions, the participant purchases the prescription and we receive the claim via streamline within approximately 10 business days. Reimbursement will be received in accordance to our reimbursement schedule. Streamline not applicable: The following are not eligible to participate in streamline: Participant or their dependents who have coverage under another health plan with coordination of benefits. Participant whose Medical coverage includes a domestic partner who is not a dependent for federal income tax purposes. The medical expenses of the domestic partner who is not a tax-qualified dependent are not eligible for reimbursement under the HRA. Participant Reimbursement Options Our reimbursement method is direct deposit. Listed below is information regarding our direct deposit process and alternative reimbursement methods: Direct deposit Aetna HRA will transfer funds electronically from the employer to be deposited directly into the participant s account. Reimbursements are processed twice a month, on the 15th and the last day of the month. notification will be sent to the employer hours prior to our reimbursements indicating the amount to be funded for the HRA reimbursements. Participant must provide a direct deposit form and a voided check from their checking account. Check Aetna HRA will provide checks issued to the participant with the employer banking information. These checks are mailed directly to the employer for disbursement to the employees; the funds will be drafted from your account when the employee cashes/deposits the check. Reports will also be provided in addition to the checks for each reimbursement. Combination of direct deposit and checks Some employees will receive checks and some will receive direct deposit into their checking accounts for their HRA reimbursements. (Participants selecting direct deposit must provide a direct deposit form and a voided check from their checking account.) THE DIRECT DEPOSIT AND CHECK OPTIONS REQUIRE THE FOLLOWING: 1. Voided check or magnetic ink character recognition (MICR) for the bank account which will be used to fund the HRA. (If only a starter check is available, provide a letter from the bank listing the employer name, routing number and account number as confirmation, in addition to the starter check). 2. Starting check number (if check option is chosen). 3. Direct deposit forms and voided checks from each employee s checking account (if direct deposit option is chosen). Report only Aetna HRA will provide semi-monthly reports, via , for the claims that we have received and processed. The employer will issue reimbursements to the participants as provided in the reports. (This option cannot be in conjunction with check or direct deposit. We do not require any banking information from the employer or employees for this option.) Run-Out Period A run-out period is the number of days after the plan year has ended, that the participants can submit claims for dates of service within the HRA plan year. The standard run-out period is 60 days. Unless otherwise specified, the run-out period will be the same for a terminated employee. Additional Requirements Completed HRA census (eligible employees) Medical Services Plan (MSP) employer form MSP census Medical Plan Design (highlight sheet) Employer s banking information (if applicable) s direct deposit information (if applicable) 4
5 MyAetnaFunds.com Once the implementation has been finalized, the Plan Administrator will be provided access to the Aetna HRA website. If additional access for Human Resources is needed, we will require their name, address, phone and fax number. Website access cannot be provided to a broker due to private employee information. The Plan Administrator can view balances and access reports. The employees will also have access to the Aetna HRA website to view their personal account information. Welcome Kit Upon final implementation, the Plan Administrator will receive an Aetna HRA Welcome Kit. The Welcome Kit will contain an Administrative Guide which provides more details on the Aetna HRA process, forms, website instructions, our Customer Service contact information and the countersigned documents. Aetna HRA Accounting will begin sending out the monthly administration invoices beginning with the HRA effective date. The Aetna HRA Customer Service team will provide support and handle all future requests. Invoicing The employer will receive their monthly invoice for their Aetna HRA administration fees via . Note: The employer will remit their Aetna HRA fees to a different address than their Aetna Medical Address. Monthly fees may be paid electronically through ACH. During the implementation process, an ACH form for the monthly fees will be provided. Next Steps After the initial implementation call, an will be provided with a confirmation of the plan information discussed during the call, and list any remaining information needed. During the implementation process, if there are any questions, the Plan Administrator will be contacted. We will follow up with the Plan Administrator until all information is received. Once all required information is received, the information will be updated in our system. We will update the Plan Administrator and/or Broker throughout the process through final implementation. 5
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