Section title: Requests for Interpretation
RFI #
2313
271 + Health Reimbursement Accounts
Description

If an employer offers an employer sponsored employee benefit giving each employee a certain dollar amount to be used for their health care expenses AND that amount is neither an Health Care Account or a Health Savings Account as defined by IRS regulation AND the employee does not "own" that HRA if he/she leaves the employer the funds are not payable to the employee, how would such a thing be reported in the 271? How would the health care insurer who may receive a 270/271 on an employee report, if they have the information, the presence of an HRA and the balance of the employer sponsored HRA back on the 271?

Additionally, what is considered a "program or plan name" with regard to EB05? Would using the EB05 to advise the provider that member has an employer sponsored HRA by returning "health reimbursement account" in EB05 an allowable use of EB05 based on the note on EB05?

Response

This can be returned, but there is no way to communicate this Health Reimbursement Account description in the 005010 X279 271 without the use of a MSG segment.
EB05 is intended to communicate a Plan Name, such as ‘Gold 123’. Plan coverage details are not permitted to be included in this element. It should not be used as a replacement for a free text MSG segment to communicate details that cannot be codified.

RFI Recommendation

Include the remaining Health Reimbursement Account (HRA) balance in the 2110C/D coverage loop for the active insurance plan coverage that the HRA applies to as follows:

EB01 = D
EB03 = 30 (and other applicable Service Type Code(s) included in the plan coverage loop)
EB04 = plan type
EB05 = plan name
EB06 = 29 for remaining
EB07 = amount remaining in HRA
MSG01 = Indicate that the amount communicated is for an Health Reimbursement Account and it’s order of applicability to the collection of patient financial plan responsibility

The recommendation to use a “D” for EB01 is based on the fact that although an HRA is not a traditional “health plan” benefit, it’s a benefit offered by the employer to offset costs of rendered health plan benefits or services. Also, please note: The rules of that guide need to be followed, as such, the minimum requirements for a compliant transaction would apply. This includes those items in section 1.4.7. Section 1.4.7.2 specifically advises that, for each plan for which the member has active or inactive coverage, a 2110C/D loop with an EB01 value equal to 1 through 8 and an EB03 value of 30 along with a plan name if one exists. The HRA information may be returned in addition to the minimum required information as described above.

DOCUMENT ID
005010X279