H&W: Minimum Threshold for Reporting HRAs to CMS

Minimum Threshold for Reporting HRAs to CMS: The Centers for Medicare and Medicaid Services (CMS) recently announced an increase in the minimum threshold for reporting by health reimbursement arrangements (“HRAs”) subject to the Medicare Secondary Payer mandatory reporting provisions. Responsible Reporting Entities (“RREs”), such as claims administrators and insurers, must provide CMS an electronic report of eligibility, enrollment, and other benefit information related to group health plans, including HRAs.  This obligation falls to plan sponsors of self-administered HRAs.

Effective October 3, 2011, only HRA coverage reflecting an annual benefit of $5,000 or more must be reported.  In determining whether HRA coverage meets this threshold, CMS looks at individual HRA balances, including rollovers from prior years.  This new threshold applies to all new or renewing HRAs that become effective on or after October 3, 2011. HRAs meeting or exceeding the $1,000 threshold previously required should continue to meet any reporting obligations until the HRA plan year renewal.