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Zane Benefits Publishes New Information on Compliant HRA Software
Date:1/27/2013

nbsp;Summary of Benefits and Coverage (SBC)
  •     60-day Material Modifications
  •     Form W-2 Reporting of Employer-Sponsored Health Coverage
  •     Internal and External Claims and Appeals Processes for Health Claims
  • According to Zane Benefits’ website, an HRA is a self-funded health plan and governed by the HIPAA Privacy Rules. Employers that offer a fully-insured health plan and sponsor an HRA often overlook their HIPAA Privacy obligations. In order to administer an HRA, the entity processing the claims receives protected health information (PHI) which is protected by HIPAA. Employers that offer a fully-insured health plan will rely on the insurance carrier to comply with the HIPAA Privacy Rules. However, the HRA compliance obligations rest with the employer. Employers that do not comply can be subject to civil penalties of up to $100 per violation.

    According to Zane Benefits’ website, an HRA is an employee welfare plan under ERISA. ERISA requires that every [welfare] plan be established and maintained pursuant to a written instrument. The written instrument or plan document serves to define what expenses are eligible for reimbursement, the amount of employer contribution, and whether the funds may be rolled over from year to year. Not only could an enforcement action be brought against an employer for failure to have a plan document, but it is difficult for the employer to prove plan terms and enforce its provisions.

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