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To document and administer an employer medical reimbursement plan correctly, first identify the exact arrangement—conventional health reimbursement arrangement (HRA), individual coverage HRA (ICHRA), or qualified small employer HRA (QSEHRA)—then put its eligibility, expenses, substantiation, claims, notices, and record controls in writing. The rules differ by design, and an employer should also determine whether ERISA applies before using a generic checklist. This U.S.-focused guide gives an operational framework; have the final plan and procedures checked against current law by qualified benefits counsel or the plan administrator.
Identify the arrangement before creating paperwork
An HRA is established and funded solely by the employer. Employees cannot fund it through salary reductions. IRS Publication 969 states: “An HRA must be funded solely by an employer.” Reimbursements generally must be for qualified medical expenses incurred after the participant becomes enrolled, and they must follow the written plan terms. See the IRS Publication 969 (2025) for the federal framework.
The phrase medical reimbursement plan does not identify one legal design. Confirm the design, sponsor, participating worker classes, coverage dates, and relationship to any group medical plan or individual insurance before drafting forms.
| Design | Core use | Administration that is distinctive |
|---|---|---|
| Conventional HRA | Employer reimbursement of eligible medical expenses under employer-defined terms. | Define eligible expenses, covered people, enrollment timing, limits, carryover, substantiation, claims, and termination treatment. Coordinate the HRA with any group health plan and HSA eligibility rules. |
| ICHRA | Reimbursement connected to individual health insurance coverage or Medicare when the applicable conditions are met. | In addition to expense substantiation, verify qualifying individual coverage through the required annual and ongoing process. Use current official model attestations and regulations. |
| QSEHRA | A separate arrangement for eligible small employers that meet the statutory conditions. | Administer coverage proof, the applicable reimbursement limit, and W-2 reporting. Confirm each current-year limit and reporting instruction in the current IRS publication. |
Governmental plans and most church plans generally fall outside ERISA, while many private-employer health plans are covered. Do not assume that an HRA label answers the ERISA question; establish the sponsor and plan status first.
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Build the governing plan file
Create one controlled plan file before accepting claims. The exact contents depend on the design and applicable law, but a complete operational file normally includes the following:
- A signed plan document and any employer resolutions or adoption materials.
- Insurance, benefits, payroll, or administrative agreements that affect eligibility, funding, or claims.
- Participant enrollment materials, notices, acknowledgments, and distribution records.
- An SPD and amendments or summaries of material modifications when ERISA applies.
- Written claims and appeal procedures, including the version in effect for each claim period.
- Substantiation records, claim decisions, payment records, balance reconciliations, and correspondence about missing information, denials, or appeals.
- For an ICHRA, coverage attestations or third-party evidence collected under the applicable verification process.
Limit access to people who need it for plan administration, payroll, compliance, or an authorized audit. Medical information should be handled with appropriate privacy and security controls, and the administrator should be able to produce an auditable history without exposing more health information than necessary.
Write terms an administrator can apply consistently
A plan document should answer the same questions for every participant. Ambiguous promises create inconsistent decisions and make appeals difficult.
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State which employee classes may participate, the eligibility service or classification rules, enrollment date, coverage period, and treatment of leaves, rehires, transfers, and changes in worker class. Identify whether dependents or other covered persons may be reimbursed and how the participant proves that relationship.
Expenses and covered people
Describe the categories of qualified medical expenses, the people whose expenses may be submitted, exclusions, and any coordination rule with another plan. A general definition should be tied to the plan’s actual benefit design; IRS Publication 502 is a reference for medical and dental expense concepts, but the plan still needs its own eligibility terms.
Timing, limits, and balances
Specify when an expense becomes eligible, the plan-year dates, annual or other reimbursement caps, and whether unused amounts carry forward. Make clear whether a claim must be submitted by a particular deadline and how the administrator treats an expense incurred before enrollment or after coverage ends.
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Do not describe an unused balance as cash payable to a participant. IRS guidance warns that distributions available for nonmedical purposes can cause HRA distributions to be taxable. State what happens to an unused balance at termination and plan-year end in a way that preserves the plan’s tax conditions.
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Evidence, claims, and appeals
List the information needed to establish the expense, amount, date, and person covered; the submission channel; deadlines; decision time frames; denial reasons; and appeal steps. State who decides claims and appeals and what happens when evidence is incomplete.
Run a controlled reimbursement workflow
Use the same sequence for every request and retain the evidence supporting each decision.
- Receive the claim. Record the submission date, participant identity, covered person, requested amount, and plan or account identifier.
- Verify identity and coverage. Confirm that the participant and covered person are eligible for the relevant date and that the expense falls within the plan year.
- Check the timing rule. Reject or return expenses incurred before enrollment when the plan does not permit them, and check any post-termination or submission deadline.
- Inspect substantiation. Confirm the service or purchase date, description, provider or merchant, amount, and proof of payment when required. The evidence must support both the medical purpose and the person who received the service.
- Apply plan terms. Match the expense to the plan’s covered categories, exclusions, coordination rules, remaining benefit, and any applicable cap.
- Resolve gaps. Ask for specific missing evidence or issue a plan-based denial. Do not approve a claim merely because the participant or merchant labels it medical.
- Decide and communicate. Approve only a supported amount, explain a denial or partial approval, and provide the appeal route and deadline required by the plan.
- Pay and reconcile. Record the approval, payment date, payment method, amount, and new balance. Reconcile the transaction to the plan ledger and payroll or benefits records where applicable.
- Preserve the file. Keep the claim, evidence, decision, payment record, and related communications together under controlled access.
Minimum claim data
| Data element | What it establishes |
|---|---|
| Participant and covered person | Who is entitled to use the benefit and whose expense was incurred. |
| Date of service or purchase | Whether the expense falls after enrollment and within the applicable plan period. |
| Description and provider or merchant | What was purchased or provided and whether it fits a covered category. |
| Amount and proof of payment | The reimbursable amount and whether the participant actually paid it, when payment proof is required. |
| Decision, payment, and balance | Why the claim was approved, reduced, or denied and how the account was updated. |
Payment cards do not remove substantiation
Debit, credit, and stored-value cards may be used for an HRA, but a card transaction avoids additional participant documentation only when an accepted substantiation method applies. A merchant-category code or card swipe alone does not prove the medical purpose unless a permitted method covers the transaction. Flag unsupported card charges, request evidence, and recover or offset an impermissible payment under the plan’s correction procedures.
Meet ERISA information and claims duties when they apply
For an ERISA-covered plan, participants need written information about how the plan operates and how to use its benefits. The Department of Labor describes the summary plan description (SPD) as the participant-facing explanation of plan operation, benefits, and claims procedures. Provide the SPD as required, and reflect a material change through a revised SPD or a summary of material modifications when applicable. See DOL Plan Information.
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Fiduciary and service-provider oversight
ERISA health-plan fiduciaries must act prudently and in participants’ interests. A service provider performing only ministerial work is not automatically a fiduciary, but discretionary authority over eligibility or benefits can change that analysis. The employer remains responsible for selecting and monitoring service providers and for ensuring that claims are reviewed fairly. The DOL explains these responsibilities in Understanding Your Fiduciary Responsibilities Under a Group Health Plan.
Use a separate workflow for an ICHRA
An ICHRA can be integrated with individual health insurance coverage or Medicare only when the applicable conditions are met. Expense substantiation is not enough: the administrator must also verify qualifying coverage under the ICHRA rules.
Annual verification
At the required annual point, obtain the participant’s coverage attestation or permitted third-party evidence using the current official form and process. Record the coverage status, verification date, plan year, and any follow-up.
Ongoing verification
Maintain the process for confirming that coverage continues during the year. Depending on the prescribed process, this may use an attestation or third-party evidence. A generic receipt checklist cannot substitute for the ICHRA coverage workflow. Use the current DOL Individual Coverage HRA Model Attestations and current IRS ACA guidance at IRS Affordable Care Act tax provisions.
Coordinate the two tests
For each ICHRA reimbursement, retain both the medical-expense substantiation and the coverage-verification record. If either test fails, pause payment, request the missing evidence, or issue a plan-based denial with appeal information.
Administer a QSEHRA as its own design
QSEHRA has separate employer eligibility conditions, coverage-proof requirements, a statutory reimbursement limit, and W-2 reporting. Do not copy a conventional HRA or ICHRA checklist and assume it is sufficient. Confirm the employer’s eligibility, obtain the required proof of coverage, apply the current-year limit, and coordinate the benefit with payroll reporting.
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Annual dollar limits and reporting instructions can change. Verify the current figures and instructions directly in the current IRS publication before setting the plan year or preparing Forms W-2; do not rely on an unofficial reproduction of Publication 15-B.
Set a defensible record-retention and privacy schedule
There is no single retention period established here for every HRA claim, plan document, tax record, and privacy-sensitive file. The appropriate period can depend on the record category, federal and state requirements, plan terms, audits, and litigation holds.
Adopt a written schedule after checking current requirements with qualified counsel or the plan administrator. At minimum, classify records separately—plan documents and amendments, participant disclosures, claims and substantiation, payments and reconciliations, tax reporting, vendor oversight, and appeals—then specify the owner, storage location, access rights, deletion trigger, and legal-hold override. Never delete a record that is subject to an investigation, audit, dispute, or litigation hold.
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| Decision axis | Questions to answer |
|---|---|
| Eligible employers and worker groups | Which employer and employee classes qualify, and how will eligibility changes be tracked? |
| Benefit scope | Will the arrangement reimburse individual premiums, other medical costs, or both under the chosen design? |
| Interaction with other coverage | How does the HRA interact with group coverage, Medicare, and HSA eligibility? |
| Budget and limits | What employer budget, annual cap, carryover rule, and termination treatment can the plan support? |
| Substantiation workload | Can the administrator validate dates, amounts, medical purpose, covered persons, and payment evidence? |
| Coverage verification | If the design is an ICHRA or QSEHRA, how will required coverage proof be collected and refreshed? |
| Participant support | Are notices, claim explanations, appeals, and accessibility responsibilities clearly assigned? |
| Payroll and benefits integration | How will eligibility, payments, balances, and reporting reconcile with payroll and benefits records? |
| Privacy and discretion | Who can view health information, and does a service provider exercise discretion that affects fiduciary analysis? |
| Reporting | What tax, W-2, or other reporting outputs are required for the design and year? |
Fix common administration failures
A claim predates enrollment
Check the enrollment date and the plan’s incurred-expense rule. If the expense is outside the eligible period, issue a clear denial citing the plan term and provide the appeal route rather than changing the rule informally.
The receipt does not identify the service
Request an itemized statement or other permitted evidence showing the date, provider, description, amount, and covered person. A bank statement that shows only a merchant and total may establish payment but not medical eligibility.
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Apply the accepted substantiation method documented in the plan. If the transaction is not covered by that method, suspend or reverse the payment as required and request supporting evidence.
A participant disputes a denial
Preserve the original claim, evidence, decision, and notice. Route the appeal to the person or body designated by the plan, apply a full and fair review where ERISA requires it, and issue the written result within the plan’s stated process.
An employee changes status or leaves
Check the plan’s eligibility and termination provisions, stop or continue claims only as those provisions allow, and reconcile any outstanding balance. Do not convert an unused medical benefit into unrestricted cash.
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Identify the effective date, update the controlled procedure and participant materials, and determine whether an SPD revision or summary of material modifications is required. Keep evidence of the distribution and use the correct version for each claim.
Launch checklist for the plan administrator
- Confirm the design: conventional HRA, ICHRA, or QSEHRA.
- Determine the sponsor, eligible classes, coverage dates, and ERISA status.
- Approve and sign the plan document and supporting resolutions.
- Define expenses, covered people, timing, limits, carryover, termination, and submission deadlines.
- Configure claim intake to capture identity, date, description, provider, amount, payment evidence, and decision history.
- Publish the claims and appeals procedure and distribute the SPD or required notices.
- Set up ICHRA coverage verification or QSEHRA coverage-proof and reporting controls where applicable.
- Test balance calculations, card substantiation, denial notices, appeals, and payroll reconciliation before the first live claim.
- Adopt a retention, privacy, access-control, and legal-hold schedule.
- Review the process each plan year against current IRS and DOL guidance.
Using this structure keeps the plan document, participant disclosures, claim evidence, payments, and oversight records aligned. That alignment—not a particular software tool or receipt format—is what lets an employer demonstrate that reimbursements followed the plan and applicable law.
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