HRA – Reminder.
Do not utilize your HRA debit card at the time of service unless:
- You are 100% sure that the amount you are being charged is the balance that is owed AFTER any deductible or network discounts have been applied.
- You are 100% sure that the provider will submit a claim into the Plan so that it can be adjudicated, and an explanation of benefits can be issued in enough time so as to timely substantiate the use of your debit card purchase or payment.
- You are 100% sure that the service, medical goods, or treatments being paid for or purchased are automatically substantiated pursuant to the Internal Revenue Code.
- You kept all your receipts and learned how to timely monitor and substantiate your card usage within the CREATE claims system.
Should there exist any doubt as to whether the transaction can be verified automatically, or if there is any question if your provider and/or medical professional will submit a clean claim and do so timely so that said the HRA debit card usage can be substantiated, do not use your HRA debit card. Instead pay for the service, treatment, or medical goods by using some other method of payment. (Preferably one that gives you points or cash back) Then wait for the explanation of benefits to be issued and submit your HRA claim request.
For those that find the aforementioned to be inconvenient or erroneously believe that it is not their responsibility to substantiate their claims, you are reminded that it is the Internal Revenue Service (IRS) that dictates how this benefit is to be administered. Meaning; they set the rules, and the Fund has to follow them.
Secondly, the “R” in HRA stands for reimbursement. The definition of the word reimbursement is as follows: The act of repaying a person who has spent or lost money. It is also important to understand that the use of the word reimbursement is deliberate as the Internal Revenue Service intent for these types of tax advantage programs was and is to provide reimbursement AFTER payment was made for the qualified expenses that are in excess of the maximum Plan benefit.
Now, in order to determine the latter, a claim has to be adjudicated first. Hence the Funds requirement to submit its explanation of benefits as substantiation for all medical and dental HRA claims. (Rx and vision expenses can be substantiated with their respective receipts provided of course; they contain all the appropriate information as explained within last month’s newsletter.)
Moreover, and as you know, the Internal Revenue Service does permit the use of debit cards to be used in conjunction with an HRA program. However, in no instance does credit card usage supersede the Internal Revenue Service’s intent (described prior) requirements or rules. Rather, debit cards were only meant to facilitate the quicker transmission of HRA payments AFTER the claims were paid and as reimbursement for only for those amounts in excess of the maximum Plan benefit.
Further, the fact that the Internal Revenue Service has worked with certain facets of the American Health Care industry and permits the latter to code the “no-brainer” of permissible expenses so that they are immediately substantiated at the time of purchase, neither means that all medical or dental services and expenses are coded this way. As a matter of fact, dentist, physician, and facility claims are not coded as such. So unless you are certain about what was written within the four bullet points at the beginning of this particular reminder……, don’t use your HRA card at the time of purchase or service at any of those entities.
Don’t like that? Got it. However, the Fund cannot fight that battle because it cannot be a registered voter. But as a registered voter you can effectuate change. If you want to see improvement in the law, you can and should express your views, thoughts and ideas to your Congressmen/Congresswoman and State Senator either verbally, in written medium, in person or in the form of your vote.
Reminder that the Plan Neither Creates Claims nor Changes Claims.
Each week, the Fund is asked to pay a claim that is coded differently than the participants expectations or just coded not to their liking. Be advised that the Plan has to pay claims as they are written. It cannot change or alter a claim. It can only reject, deny, or process and pay a claim.
Therefore, if you think that you are adversely affected because of a purported discrepancy in either the accuracy or correctness of a claim submitted into the Plan on your behalf, you must address such issues or concerns with the accountable party. Which again would be the entity responsible for issuing the claim. Further,
- The Fund is never an issuer of dental, medical, pharmaceutical or vision claims. As such we cannot alter, modify, or revise a claim. And,
- The Fund must adjudicate and/or process claims as they are presented. And,
- The Fund will be accountable for only those matters or issues that it is required to provide as described within the Summary Plan Description book or mistakenly causes. And,
- Having the expectation that the Fund will be responsible or solve for matters that are outside of its purvey is flawed and will lead to disappointment.
Reminder of Submission Dates for Self-Payments.
Despite the due date being clearly delineated within the shortage of hours’ notice that participants receive, not to mentioned annoyingly emblazoned in pop-up banners within the Funds website and displayed and discussed within newsletters, there are those that still try to convince the Fund office to accept their Shortage of Hours payment after the due date.
Not as interesting as it is strange, it is always the same people that are late. Weirder still is the fact that they always use one of the following excuses for said lateness:
- I was never informed when the payment was due.
- I misplaced the notice and/or did not open my mail.
- I thought my HRA would automatically pay for part of the shortage, and I would be billed for the difference.
Spoiler Alert: None of these excuses “passes muster” or “cuts the mustard.” Let me explain.
If you read the first paragraph of this particular reminder you would know that the first excuse doesn’t hold any water.
Further, and for the reason that within that same shortage of hours’ notice the Fund specifically describes how and under what circumstances the participants HRA will be automatically debited, and because that exact scenerio is precisely explained within the HRA FAQ, SPD (Summary Plan Description Book) and prior newsletters, the third excuse doesn’t hold up either.
As to the second bullet point. We get it. You’re busy. We are as well, and sometimes things just happen. But, let me be clear, the Fund cannot make allowances for your choices and things outside of the Funds control. Moreover, it should not be expected to.
To that end, listed directly below are the due dates and times that each quarter of coverage payment must be made by:
| Quarter of Coverage | Unless Stated Otherwise, Your Self-Payment is Due No Latter Than |
|---|---|
| January, February, March | 12:00 P.M. on the last business day of the month of December that precedes the quarter of coverage |
| April, May June | 4:30 P.M. on the last business day of the month of March that precedes the quarter of coverage. |
| July, August, September | 4:30 P.M. on the last business day of the month of June that precedes the quarter of coverage. |
| October, November, December | 4:30 P.M. on the last business day of the month of September that precedes the quarter of coverage. |