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Putting the Pieces Together- HRA, HSA &
FSA-Where Do They Fit?
Presented by
Rob Thurston, President, HR Consulting Group, Inc.
March 13, 2006
Putting the Pieces TogetherPBasic Plan DesignsPCase Study Review
PPitfalls in Plan DesignPWhere do we go from Here?
Who will be Covered?PFirst Question to ask: Who will
be covered?PHealth FSA & HRA B Any
employee, can be employer defined
PHSA Any Individual, not entitled to medicare or claimed as a tax
dependent & is enrolled in a qualified HDHP
Is there a Qualified HDHP Plan?
PBe careful B not just any plan will do
PAmounts are indexed B make sure plans will be updated to meet
annual requirementsPShould the employer offer more
than one option?
How can Employee Pay?PHealth FSA B Employee can pay
pre- tax through a S125 Cafeteria Plan
PHRA B Employee does not pay into HRA portion, however
employee can pre-tax the HDHPPHSA B Employee can pre-tax both the HDHP and the HSA contribution through a S125
Cafeteria Plan
What will Employer Pay?PHealth FSA B should employer
make a contribution?PHDHP B will employer increase contribution towards HDHP?
PHRA B How much does employer want to put into the account?PHSA B Does employer want to
make a contribution B warning, money will belong to employee!
How will Unused Amounts be Handled?
PHealth FSA B will employer allow 2 2 month extension to pay
claims?PHRA B will employer allow
employee to take money with them? Will there be a limit placed
on the liability?PHSA B if employer money is
deposited, will employer have problem over loss of control of
funds?
What Type of Expenses will Be Eligible?
PHealth FSA B should be limited scope or full FSA or both?
PHRA B should be limited scope?PHSA B employer has no control
herePCoordination if all three are
present
Company CulturePHow will plan design be viewed
by employees?PWhat is normal communication
process used?PWhat goals are being set by
Corporation?
Case Study 1PSmall Employer under 100 livesPDid not have HDHP that qualified
for HSAPGoal was to minimize rate
increases (2005 has 23% rate increase)
Case Study 1PWent with PPO plan with
$3,000/$5,500 Deductible and $5,000/$10,000 OOP
PHad general purpose FSA and Dental Plan
PWanted more control over money, did not want to contribute
to HSA
Case Study 1PLets Look at Single Coverage
Design:
PHealth FSA B Employee can contribute up to $1800 B FSA pays
firstPHRA B Employer contributes
$1200PHDHP B Expenses covered by
InsurancePOOP B Employee exposure
$2,000
Case Study 2P1500 employees, multiple
locations located nationwidePWent from self-funded PPO &
HMO option to HDHPPOffered 2 Self-funded HDHP
designs:BHigh Option has $1000/$2000
Deductible and $3000/$6000 OOP MaxBLow Option has $2000/$3000
Deductible and $5100/$10200 OOP Max
Case Study 2POffered 2 FSA Plans, Limited
Scope & Full FSAPHad S125 Plan including HDHP,
FSA, Dental and VisionPAdded HSA in 2005 Plan Year
Case Study 2PSlight Drop in FSA ParticipationP63% Elected to Participate in HSA with average monthly
contribution of $75PMajority elected High Option,
even though premium was higherPClaims decreased by 43%
Case Study 2PEmployer exceeded goal of reducing claim cost and minimizing premium
increasesPInstallation was not without
problems: Employee view, HSA Trustee Issues & Increased workload
for HR StaffPCorporate concerned that employees
are not getting healthcare when needed
Case Study 2PIn 2006, added a third option to plan that did not qualify for HSA
($500 Deductible)PPremium did not increase for
2006PEmployees did not go to lower deductible plan B most stayed
with what they had in 2005
Caution B Avoid These Potholes!PMid-Year Changes
BHSA can be added mid-plan year, but this can be messy and some options are still being
discussed by IRS (i.e. changing to a limited scope FSA, may not be valid)
PNon-DiscriminationBBefore making contributions to an HSA, an
employer should be sure to review the comparability rules...if it is not part of a S125
Cafeteria Plan
Caution B Avoid These Potholes
PCOBRA applies to HRA'sBThis can increase liability in case of divorce as the full balance of the account must be
available to both the employee and ex-spouse
PERISABMake sure that all plan documents, SPD's
and employee communications are accurate---watch for ERISA wording that can make a non-
ERISA HSA and ERISA plan by inference
Questions?PFor more information, contact:PRob Thurston, HR Consulting Group,
Inc.P(801) 765-4417