August 6, 2010

Mandatory Medicare Reporting for HRAs Clarified

As mentioned in the June Benefit Beat (Updated Information: Mandatory Medicare Reporting for HRAs), the rules relating to the Mandatory Medicare Reporting for health reimbursement arrangements (HRAs) have been clarified.  TheCMS Group Health Plan User Guide has been updated to reflect this.  Of particular note, both “free-standing” and “imbedded” HRAs must comply with the mandatory reporting. 

According to the User Guide, only HRA coverage that reflects an annual benefit value of $1000 or more is to be reported. HRAs with an annual benefit amount of less than $1000 are exempt from reporting.

Responsible Reporting Entities (RREs) are not required to report HRA coverage information until their assigned file submission timeframe in the 4th Quarter (October, November, and December) of 2010, or 1st Quarter (January, February, and March) of 2011.


The information contained in this Benefit Beat is not intended to be legal, accounting, or other professional advice, nor are these comments directed to specific situations.

As required by U.S. Treasury rules, we inform you that, unless expressly stated otherwise, any U.S. federal tax advice contained in this Benefit Beat is not intended or written to be used, and cannot be used, by any person for the purpose of avoiding any penalties that may be imposed by the Internal Revenue Service.

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