Allyson Burke

As open enrollment season approaches, employers may consider adopting a health reimbursement arrangement (HRA) or adapting their current one. HRAs have never been more popular. A July 30, 2007, Wall Street Journal article, “Employers Turn To Alternative For Insuring Staff,” even discussed HRAs as a substitute for traditional employerprovided health coverage.

When considering HRAs, take care to understand the COBRA implications. One difficulty is that the IRS’ final COBRA regulations were issued before HRAs came into existence, and Notice 2002-45, the decisive
HRA resource, devotes only two paragraphs of its 14 pages to COBRA.

Five difficult HRA areas are:

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