HRAs, as they are lovingly called, have undergone a major transformation over the last six years due to the ACA. With all the guidance coming out from different sources, it’s hard to keep track, let alone stay compliant. One day you can use them to reimburse premiums. The next you’re told you can’t by the IRS, but there are still those in the marketplace that said you could. Then we had to modify how HRAs were “integrated” into our group health plans. Because if they weren’t, you might be subject to a penalty for not offering minimum essential coverage. Now there are calculations to consider with HRAs regarding affordability. While all of this “new” guidance is in effect, employers and their advisors are still trying to build compliant plan designs with HRAs, FSAs and HSAs, working together.