Can retirees have Medicare premiums reimbursed through former employers’ HRA?


Issue:

Your company has elected to allow retired employees to stay on the same health plan offered to active employees, so many of those covered by your health insurance are retirees on Medicare. Can you reimburse their Medicare premiums through a retiree health reimbursement arrangement (HRA)?

Answer:    

Yes. The IRS has provided that reimbursements for insurance covering medical care expenses, as defined in Internal Revenue Code Sec. 213(d)(1)(D), are allowable reimbursements under an HRA, including amounts paid for premiums for accident or health coverage for current employees, retirees, and COBRA qualified beneficiaries.

Internal Revenue Code Sec. 213(d)(1)(D) defines the term "medical care" as amounts paid for insurance (including amounts paid as premiums under Part B of Title XVIII of the Social Security Act, relating to supplementary medical insurance for the aged) covering medical care referred to in subparagraphs (A) and (B) or for any qualified long-term care insurance contract (as defined in Internal Revenue Code Sec. 7702B(b)).

As a reminder, HRA contributions are only made by the employer, and they are tax free for participants and tax deductible for employers. Reimbursements under an HRA generally can be made to current and former employees, along with their spouses and dependents, an employee’s child under the age of 27, and spouses and dependents of deceased employees.

Source: IRS Notice 2002-45, Section II and IRS Publication 969, http://www.irs.gov.

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