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HEALTH REIMBURSEMENT ARRANGEMENTS HRA’s ADMINISTRATION SUBSTANTIATION Each medical expense submitted for reimbursement must be substantiated prior to reimbursement. Notice 2002-45, Sec II, 2002-28 IRB 93. See also Rev. Rul. 2003-43, 2003-21 IRB 814, with regard to the application of the substantiation rules in connection with the use of debit or credit cards. ADMINISTRATION INFORMATION REPORTING There are no information reporting requirements applicable to amounts that an employer allocates to HRA’s. HRAs as employee welfare benefit plans under ERISA may be subject to annual reporting on Form 5500. Although Rev. Rul 2003-43, 2003-21 IRB 935, issued on May 6, 2003, states that payments made under employer-provided expense reimbursements to medical service providers through debit, credit and stored value cards are reportable by the employer on form 1099-MISC, the Act provides an exception from the reporting provisions for medical care payments made under HRAs and FSAs. ERISA APPLICATION ERISA - An HRA is an ERISA plan subject to reporting and disclosure obligations. EFFECTIVE DATE/CUT-OFF DATE Effective Date: Status clarified in Notice 2002-45, 2002-28 IRB 93. Cut-off Date: NONE. | ||
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