Frequently Asked Questions

A Health Reimbursement Account (HRA) is a tax-advantage Plan benefit that allows you to pay for a wide range of medical expenses considered to be qualified under IRS Section 213 of the Internal Revenue Code, including self-payment premiums to the Health and Benefit Plan, using accumulated credits.

The Board of Trustees have chosen Create as the market leader in consumer directed healthcare benefit accounts, to assist the Plan in providing participants with 24/7 access to the allowances within their HRA’s.

The HRA is a benefit of the Lake County Indiana NECA – I.B.E.W. Health and Benefit Plan. Eligible employees and participants can accumulate HRA benefit credits to receive reimbursement for qualified, medical, dental, vision and Rx expenses.

Further, and for the reason that the HRA is a benefit, it is the Board of Trustees that determines the scope of how it is set up and used – including the allowance you and each employee will receive

Access to your account is only a few clicks away at mycreatehealth.com or through their app.

Didn’t download the app yet? What are you waiting for? Go to your app store. Type the word “MyCreateHealth” into the search function and follow the instructions to download.

For first time users, the following login instructions will work for either the app or website portal. Or if you prefer, you can view a site tutorial by copying and then pasting within your browser the link directly below:

HRA accounts are credited at the same frequency in which your eligibility is credited. Meaning: the amount of excess contributions earned in a work quarter will be tallied and subsequently credited to an employee’s HRA account during the corresponding quarter of coverage.

Please note that the middle column is deliberately left blank to emphasize the fact that there exists an administrative “lag quarter” that separates a work quarter from its corresponding quarter of coverage. Meaning: Excess contributions in any work quarter do not get credited in the subsequent calendar quarter of coverage. Rather, it skips a quarter.

The initial balance of your HRA account is calculated by tallying the total amount of employer contributions in excess of 450 that are received on your behalf within the first calendar quarter AFTER obtaining initial eligibility or reinstatement of eligibility and multiplying that number by the “value” of each hour contributed. That amount is then credited to your HRA account in the quarter of coverage that corresponds to the work quarter in which the excess was earned.

After your account is established, the total amount of employer contributions submitted on your behalf in each subsequent and successive calendar quarters will be tallied. If you worked greater than four hundred and fifty hours (450) during the previous fiscal quarter, the hourly rate or value of those “excess” hours will be credited to your HRA. The crediting of your HRA account will occur in the quarter of coverage that corresponds with the work quarter in which the excess of contributions occurred.

Active employees can amass a total balance of $17,000.00 within their HRA’s. Retired participants can amass $25,000.00.

You can use HRA monies to make self-payments, but the Plan does not permit the use of HRA allowances to make COBRA payments.

Provided you utilize the HRA allowance for an eligible expense, reimbursements made from the HRA are not considered part of your income and are not taxed.

With the exception of COBRA payments and those expenses that are reimbursable by any other source such as another insurance company, the Board of Trustees have permitted all other qualified expenses as described under Section 213 of the Internal Revenue Code. This would include, but is not limited to deductibles, coinsurance costs, prescription drugs or other types of out-of-pocket costs. Please check the Health and Benefit Plan’s Summary Plan Description Book for exact details of what the HRA will reimburse for and what it will not.

Immediately.

Reimbursement requests that exceed your account balance will be reimbursed up to the amount available in the account. Please remember that services must have been rendered before they will be reimbursed. If you spend all of your HRA benefit allowance and still have an amount you owe, you will need to bridge that gap with money out-of-pocket.

Yes. Throughout the year, you need to keep your original receipts and documentation for prescriptions and health related expenses for all transactions (including debit card transactions), so you’ll have them if needed to verify a claim. The IRS requires that all transactions are validated, including the debit card transactions.

In most cases involving debit card transactions, the electronic data that the Plan or its third-party administrators have will be sufficient to accommodate this requirement. If the Plan or its third-party administrator does not have the electronic data or if the transaction cannot be validated, you will be contacted, and you’ll be asked to provide documentation with receipts. Make sure you respond promptly to any request for receipts. Failure to do so can result in:

1. The expense being labeled as ‘ineligible,’ in which case you would be obligated to reimburse your HRA.
2. The temporary deactivation, and if proper documentation is not received within sixty calendar days, the permanent deactivation of your debit card.
3. The amount of the non-qualified expense being reported to the IRS as deferred compensation, making those funds taxable.

In most circumstances, you will not need to submit a manual request for reimbursement. If the situation arises, requests can be made using an HRA Reimbursement Claim Form. This form is available on the Plan’s website or by calling 219-940-6181. Completed reimbursement requests should be mailed to:

Create

PO Box 161357

Altamonte Springs, FL 32716.

Or you can fax the completed form to the following toll-free number: 844-791-8317.

For faster processing, you may upload completed forms and documentation on the create portal or mobile application.

Generally, you have 365 days from the service date to submit a claim for consideration for reimbursement. However, should you be terminated from the Lake County Indiana NECA – I.B.E.W. Health and Benefit Plan, your debit card will be deactivated upon termination and you will be provided sixty (60) calendar days to manually submit any claims for consideration for reimbursement.

Let's start with what it isn't.

It isn't a participation trophy. It isn't a constitutional amendment. It isn't proof that the universe finally decided you deserve free money.

It's a convenience.

A remarkably useful little piece of plastic designed to eliminate paperwork—not common sense.

Think of it this way: the HRA debit card exists for the same reason automatic doors exist. They're faster. They're easier. But if someone repeatedly walks into the "Exit Only" door because reading signs feels oppressive, eventually someone installs a lock.

The card allows you to access your available HRA balance without filling out reimbursement forms every time you incur an eligible, known out-of-pocket medical or dental expense. In most cases, that amount has already been determined in your Explanation of Benefits (EOB), so everyone—the participant, the provider, and the Plan—knows exactly what is owed.

That's the magic.

The card works because everyone agrees to follow the same rules.

Abuse the card, however, and something equally magical happens: it stops working.

Not because anyone is angry. Not because someone at the Fund Office woke up craving conflict. Simply because the card is a convenience, and conveniences have a funny habit of disappearing when they're repeatedly misused.

It's a bit like borrowing your neighbor's lawn mower. Return it with a full tank and a thank-you, and they'll probably lend it to you again. Return it with three missing wheels and insist they're being unreasonable, and congratulations—you've just discovered how privileges become memories.

The good news? This is incredibly easy to avoid. Spend fifteen minutes with the HRA section of your Summary Plan Description (SPD). It explains the rules once, so no one has to explain them twice, three times, or through an increasingly awkward series of emails that all begin with, "As noted in the SPD..."

Here's a revolutionary idea: before assuming the card is broken, unfair, or somehow conspiring against you, consider the possibility that it may simply be following the rules you skipped over.

Then use the card only for eligible expenses, only for the amount you actually owe, and only when that amount has already been determined, as described in the SPD. That's it. No drama. No paperwork. No problems.

The HRA debit card isn't the benefit.

Your HRA is the benefit.

The debit card is simply the shortcut.

Treat the shortcut well, and it keeps making life easier. Treat it like the rules are merely heartfelt suggestions, and you'll discover that even a MasterCard can't purchase immunity from common sense.

Pursuant to IRS mandates, HRA benefit credits can only be utilized for remaining eligible expenses AFTER the insurance provider, this Plan, makes its payment or adjudicates for co-payments, coinsurance, deductibles etc.

As such, known expenses are those that are identified within this Funds medical and dental explanation of benefits (EOB’s) as the participants responsibility.

Stated slightly differently, participants are advised that they are not to utilize their debit card for medical, dental or visions expenses PRIOR to the claim being adjudicated by the Plan

IRS regulations require you to immediately repay the amount back to the Plan if you have “mistakenly” used your debit card to pay for an expense prior to the Plan adjudicating that claim or claims.

In addition, the Plan requires that full remuneration is to occur within sixty days (60) from the date of the transaction. Should payment not be received within the sixty (60) day period, the amount of the disbursement will be reported to the Internal Revenue Service as deferred compensation, making those monies taxable, and your debit card will be permanently deactivated.

Further, and for the reasons that both the HRA provisions of this Plan and the Internal Revenue Service’s regulations are well documented and explained, the Plan will neither:

1. Wait for the participant to first get reimbursement from the provider before they repay their HRA account; nor,
2. Adjudicate the claim and apply any Fund payment as an accumulated HRA credit.
3. Entertain the periodic repayment of that obligation, nor,
4. Obtain, chase down, get a hold of, or find a provider’s bill or claim nor intercede in any way with the participants provider because the participant is unwilling and/or has a general malaise toward taking personal responsibility for incorrectly utilizing the HRA debit card.

Your account can be used for eligible medical expenses only, and you are responsible for reimbursing your account if the card is used either accidentally or intentionally for an ineligible expense.

When this occurs, either the Plan or its designated representative will notify you within the HRA transaction portal of any ineligible purchases that are made with your debit card or for that matter, of any submission requiring further documentation, substantiation or your attention.

Should this occur, you will be required to pay back the money to the Plan within sixty (60) calendar days. During that time period your card will be temporarily disabled. Should you fail to make the payment within the sixty (60) day repayment period, the amount of the disbursement will be reported to the Internal Revenue Service as deferred compensation, making those monies taxable, and your debit card will be permanently deactivated.

Consequently, if you utilized the HRA debit card to pay for an ineligible expense and failed to timely reimburse the Plan for said purchase, you must report it in your annual income tax filing and pay the related income taxes and applicable IRS tax penalty, if any.

While you can use your debit card to pay for some over-the counter medicines, please keep in mind that you may be asked to submit receipts and documentation for these purchases. The IRS has changed the law to cover some over-the-counter drugs, including antacids, allergy medicines, pain relievers and cold medicines. For the exact list of what is covered, visit www.irs.gov.

The card will be declined if ‘swiped’ for more than your available balance. Simply ask your provider to ‘swipe’ the card for your available balance and pay the difference out-of-pocket. Another option would be to pay the amount yourself and submit a reimbursement request with your receipt to the address provided on the claim reimbursement form.

You can still use the card to pay the bill by writing your debit card number on the invoice and mailing it in, or by providing the card information over the phone to the physician’s office.

After the debit card is ‘swiped,’ the system verifies that adequate funds are available in your account, and that the expense is from a qualified merchant. If these checks hold true, the funds are then deducted automatically from your account. If these checks prove negative, the transaction is denied. If the transaction is denied, then another method of payment must be used.

You are provided a debit card with your name personalized on it. Only the individual whose name is on the card can use the card when making a health care-related purchase, but the purchase can be for any dependent covered under the Lake County Indiana NECA – I.B.E.W. Health and Benefit Plan at the time services were rendered.

No. The card only allows processing of health care expenses reimbursed through the Lake County Indiana, NECA – I.B.E.W. Health and Benefit Plan and only accepts transactions using providers of authorized services.

No. The HRA is not portable. Meaning; you cannot take it with you.

Participants who find themselves in this situation will have sixty (60) days from the date of termination to manually submit out-of-pocket expenses that were incurred while they were covered under the Plan. After sixty (60) days, any remaining balances within a participants HRA account will be forfeited

No. As stated within the Plan’s Summary Plan Description Book (also found within this website) the HRA benefit is funded solely by employer contributions.

Really?

You’re kidding right?

Someone please queue up Billy Preston’s seminal 1974 hit “Nothing from Nothing” while we open some eyes here. “Eh-hem,” simply put, once any HRA benefit credit is depleted, you are responsible for paying for any additional out-of-pocket costs out of your own monies.

Provided you are doing unit work covered under an IBEW collective bargaining agreement, and AFTER you accumulate HRA benefit credits, the card will again be available for you to use, or you can electronically or manually submit claims for reimbursement once again.

If your card is lost or stolen, report it as soon as possible by contacting the Health and Benefit Fund Office at 219-940-6181. There is a five dollar and two cent ($5.02) replacement fee that must be satisfied prior to a new card being issued. Please be advised that the replacement fee cannot be debited directly from your HRA account and must be made directly to the Fund Office by check.

Yes. If:

1. Your provider or merchant does not accept MasterCard debit cards.
2. You choose not to use your debit card.
3. Your debit card was temporarily deactivated, or
4. Permanently turned off.

Simply pay for your expenses and either submit a request for reimbursement electronically or manually submit a reimbursement claim form along with the receipt for the eligible expense(s) to Create.

If your coverage terminates, the following will occur:

1. Eligibility for dental, health, HRA, life-insurance, pharmaceutical, and vision benefits cease for you and any eligible dependents.
2. Your HRA (Create) debit card is deactivated, and you will have sixty-days days to manually submit claims for reimbursement that were incurred within three hundred and sixty-five days preceding the termination from the Plan.
3. Regardless of subsequent reinstatement, after sixty-days any balance within your HRA account will be forfeited. Meaning; the HRA allowance does not travel with you. As stated directly above, you will have a limited time period of sixty-days to submit additional requests for reimbursement of qualified medical expenses incurred while you were covered under the Plan, and, at the end of that period, the account balance will be forfeited.

No. As stated within the Plan’s Summary Plan Description Book (also found within this website) the HRA benefit is funded solely by employer contributions.

Yes.

YES! You must do so “even” for debit card transactions.

On that note, all participants are reminded that if the Plan or its designated third-party administrator believes that further substantiation is warranted, the participant MUST present the corresponding receipt. Failure to do so may result in the transaction being cancelled, and/or repayment to the Plan by the participant, permanent deactivation of the participants HRA debit card and a tax obligation for the participant.

Participants who have issues with this and wish to argue their position that either their submission or they are special and warrant an exemption or that it wasn’t their fault, may do so with the Internal Revenue Service.

Three things:

1. At first, your HRA debit card will be temporarily deactivated. You will have sixty calendar days from the date of the notice to submit the requested proper supporting documentation.
2. Should you fail to submit the proper supporting documentation during that sixty-day time span, your HRA debit card will be permanently turned off. And,
3. The amount of the unsubstantiated disbursement will be reported to the IRS as deferred compensation, making those funds taxable.

No.

We appreciate the optimism.

Unfortunately, this is one of those situations where your request and the Plan rules are like oil and water. Both are perfectly legitimate. They just have no interest in becoming friends.

The answer is no.

Not because the Plan is upset with you.

Not because someone enjoys saying "no."

And certainly not because a secret committee meets every Tuesday to determine who shall forever be denied the joy of purchasing ibuprofen with a plastic card.

The answer is no because the debit card is a convenience—not a vested benefit.

Think of it this way.

Imagine your favorite coffee shop revokes your mobile ordering privileges because you repeatedly failed to pick up your orders.

They haven't banned you from coffee.

They simply ask you to come inside and order at the counter like everyone else.

Same coffee.

Different process.

You've simply lost the shortcut.

That's exactly what happens here.

Your HRA benefit remains fully available. You may still receive reimbursement by submitting your claim electronically through the participant portal or mobile app, or by submitting a paper reimbursement request with the required documentation.

The destination hasn't changed.

Only the route has.

First, remember that there are only four reasons that would cause deactivation to occur. Either:

• The participants chose not to rectify their improper use of the card at all, or,
• The participants chose not to address the matter in a timely manner, or,
• The participant chose not to address the matter with sufficient action or documentation in a timely manner in order to thwart the permanent deactivation of their card.
• The participant lost coverage under the Plan.

Secondly, reread those four points and keep in mind the old adage …., “If the shoe fits…., wear it!”

Thirdly, keep in mind that the HRA debit card is a relatively new feature of this benefit. Meaning; prior to its introduction a few short years ago, the only way to receive this benefit was to submit a manual claim. Stated more concisely, you survived without the debit card prior, and we are relatively certain you will again.

Fourthly, take the following action:

1. Click on the following link: https://www.merriam-webster.com/dictionary/permanently
2. Decide if you are going to submit future reimbursement requests electronically through the portal or app, or manually by completing the reimbursement form and submitting it along with your receipts into Create.

Fifth, and as stated in previous communications on this matter, recognize that the deactivation of your debit card does not mean that you no longer have access to this benefit. You still do and as described directly above you can receive the benefit through electronically filing a claim or manually filing the claim.

Sixth, admittance is the first step, or so they say. So come to the realization that it happened and then get on with your life.

Lastly, you can always write an appeal. That is your right. If you elect to do this, it helps if your written request lists all the facts, dates, names and any other information you think is pertinent to support your argument that you were neither involved in whole nor in part in the card’s deactivation.

By the way, and not unsimilar to the proper usage of the HRA debit card, the appeal process is also clearly delineated within the Plan’s Summary Plan Description (SPD) Book. A copy of which has been conveniently placed within this very website, under the Healthcare tab.

If, due to a shortage of hours, you are in danger of losing your eligibility under the Plan and have an HRA benefit balance in an amount greater than the quarterly total of your shortage of hours, your HRA benefit balance will be automatically debited to be used to coverer the full quarterly shortage of hours so that you and your family maintain eligibility with the Plan.

The day and time that a participants HRA benefit balance will be automatically debited is solely determined by the Plan and will vary as needed to ensure that the Participants shortage of hours payment arrives on or before its due date. Further, the Plan’s automatic debit will supersede any other pending debit or HRA request.

Because the Plan has an obligation under ERISA to administer its rules consistently and impartially.

If one participant permanently loses debit card privileges under the Plan's established rules, but another participant receives a second, third, or fourth chance simply because they ask persuasively—or loudly—that wouldn't be fairness.

It would be favoritism.

And ERISA has an extraordinary dislike for favoritism.

There's another practical consideration.

By the time a debit card reaches permanent deactivation, the Plan has already invested a surprising amount of time trying to prevent that outcome.

Someone identified the missing documentation.

Someone generated notices requesting receipts.

Someone tracked deadlines.

Someone reviewed whatever documentation was—or wasn't—submitted.

When required by IRS regulations, someone completed the appropriate tax reporting.

And, more often than not, someone spent considerable time explaining that "permanent" is, in fact, intended to mean... permanent.

None of this should come as a surprise.

The Plan has explained the debit card rules repeatedly over the years, including:

• The materials provided when debit cards were first issued;
• Numerous Fund newsletters;
• The Summary Plan Description (SPD);
• The HRA section of the Fund's website;
• The HRA Frequently Asked Questions;
• Notices displayed within the participant portal when documentation is requested; and
• Presentations at membership meetings over several years.

Here is a fascinating observation: people rarely read instructions until after discovering why the instructions existed.

This is one of those occasions.

Finally, let's discuss the word permanent.

It's one of those wonderfully straightforward words that English has managed not to complicate.

Permanent doesn't mean:

• "Until I explain my side."
• "Until I pay the taxes."
• "Until I eventually find the receipt."
• "Just this once."

It means the privilege of using the HRA debit card has ended.

Fortunately, that's not the same thing as losing your HRA benefit.

Your HRA funds remain available exactly as before. The only difference is that future reimbursements will be processed through the Plan's standard claims procedures.

In other words, you've lost the express lane—not access to the highway.

If you believe your card was permanently deactivated in error or that the Plan failed to follow its procedures, you always have the right to appeal in accordance with the claims and appeals procedures described in the Summary Plan Description.

Because while the debit card may be permanent, your right to due process under the Plan most certainly is not.

First, resist the urge to conclude that the debit card woke up one morning, questioned its purpose in life, and decided to retire early.

Plastic, as a general rule, is not known for making existential decisions.

A permanently deactivated debit card almost always traces back to one of only four circumstances:

• You chose not to respond to a request for additional information.
• You responded, but not within the required timeframe.
• You responded, but the information provided did not satisfy the Plan's documentation requirements.
• You are no longer eligible for coverage under the Plan.

Notice a pattern?

Three of the four have remarkably little to do with the card itself.

The card is merely the messenger.

As history has repeatedly demonstrated, blaming the messenger has an extraordinarily poor success rate.

Now for the good news.

The HRA debit card is simply a convenience.

It's the drive-through window—not the restaurant.

For decades, participants received HRA reimbursements without debit cards.

They submitted claims, attached receipts, and were reimbursed.

Civilization survived.

Remarkably, so did everyone else.

That process still exists today.

If your card has been permanently deactivated, your HRA account has not suddenly evaporated into the same mysterious place where socks disappear during laundry.

Your benefit is still there.

You simply access it the traditional way.

You have two options:

• Submit your reimbursement request electronically through the participant portal or mobile app; or
• Complete a reimbursement form and submit it, along with your supporting documentation, through the Plan's claims process.

In other words, you've lost a shortcut—not the destination.

If you believe your card was deactivated in error, you also have the right to appeal.

That's not merely a courtesy; it's part of the Plan's claims and appeals procedures.

A persuasive appeal generally includes the relevant facts, dates, correspondence, documentation, and any other information supporting your position.

And finally, one small observation.

The same Summary Plan Description that explains how the debit card works also explains how to appeal a decision involving the debit card.

It's almost as though the people who wrote the Plan anticipated someone might someday ask this exact question.

They did.

You'll find the appeals procedures in the Summary Plan Description, available on this website under the Healthcare tab.

Because sometimes the fastest way forward isn't finding a loophole—it's discovering that someone thoughtfully left you a map.

Imagine trying to pay the check before the restaurant has finished adding up the bill.

That's essentially what happens when an HRA debit card is used before the Plan has adjudicated a claim.

The HRA debit card is designed to pay known, eligible, out-of-pocket expenses—not estimated ones, anticipated ones, or optimistic guesses.

Until the Plan has processed the claim and determined what you actually owe, no one knows the final amount.

That isn't bureaucracy.

That's arithmetic.

If you accidentally use your debit card too early, the solution is refreshingly simple.

Repay the amount to the Plan immediately.

Why?

Because Internal Revenue Service regulations require it.

The Plan didn't invent this rule any more than the speed limit invented gravity.

Both simply exist, and pretending otherwise rarely improves the outcome.

The Plan requires repayment within sixty (60) days of the transaction.

If repayment is not received within that time, federal tax rules require the amount to be reported to the Internal Revenue Service as taxable compensation.

In addition, your HRA debit card will be permanently deactivated.

Fortunately, avoiding all of this requires considerably less effort than dealing with it afterward.

The Plan cannot wait until your provider eventually issues a refund.

It cannot "hold" the transaction until the claim catches up.

It cannot convert a future benefit payment into repayment after the fact.

It cannot accept installment payments.

And it cannot spend weeks tracking down provider bills, negotiating with medical offices, or unwinding transactions that began with a card being used before it should have been.

Not because the Plan lacks compassion.

Because the rules don't change simply because the paperwork is inconvenient.

The HRA debit card works beautifully when it's used exactly as intended: after your claim has been processed, after your Explanation of Benefits identifies your responsibility, and after you know exactly what you owe.

Think of the debit card as the final chapter of the story—not the opening paragraph.

Get to the ending first, and the card works exactly the way it was designed to.

First, don't panic.

You are hardly the first person whose dentist said, "That'll be due today," while the Plan was provided the opportunity to determine what, if anything, you actually owed.

The problem isn't that you paid your dentist.

The problem is how the payment was made.

An HRA debit card may only be used for known, eligible out-of-pocket expenses.

Until the Plan has processed the claim and issued an Explanation of Benefits (EOB), the amount you ultimately owe has not yet been determined.

In other words, the dentist knows what they billed.

The Plan knows what it covers.

Only after both pieces come together does anyone know what you actually owe.

That's why the card must wait.

If your debit card has been permanently deactivated because it was used before the claim was adjudicated, don't worry—you have not lost your HRA benefit.

You've simply lost the convenience of paying directly with the debit card.

Your HRA account remains available for eligible expenses.

Going forward, you'll simply submit your eligible out-of-pocket expenses to the Fund Office for reimbursement after your claim has been processed and your responsibility has been established.

Think of it as the difference between losing your driver's license and losing your car.

One changes how you get somewhere.

The other changes whether you can get there.

In this case, you've lost the shortcut—not the benefit.

The good news is that avoiding this situation in the future is surprisingly simple:

Wait until you receive your Explanation of Benefits (EOB), confirm the amount you are actually responsible for paying, and then seek reimbursement from your HRA for that eligible expense.

It may require one extra step, but it ensures your HRA remains compliant with Internal Revenue Service regulations—and keeps everyone, including you, out of unnecessary trouble.

The HRA benefit hasn't disappeared.

Only the piece of plastic has.

It's an understandable reaction.

Unfortunately, it's usually not an accurate one.

Let's walk through what likely happened.

Let's say, for example, you paid your dentist the entire bill using your HRA debit card before the Plan had an opportunity to process the claim.

Now ask yourself a simple question:

If the provider has already been paid in full, what incentive do they have to submit a claim to the Plan for reimbursement?

Exactly.

From the provider's perspective, the account may already show a zero balance.

Their bill has been paid.

Their work is finished.

The Plan, however, has never had the opportunity to determine what portion of that bill it would have paid and what portion, if any, was actually your responsibility.

And that's precisely why there is no Explanation of Benefits (EOB).

No processed claim means no adjudication.

No adjudication means no Explanation of Benefits.

And without an Explanation of Benefits identifying your actual out-of-pocket responsibility, there is nothing to substantiate the debit card transaction.

It's a little like turning in an expense report for a business trip that your employer never knew you took.

You may very well have spent the money—but the documentation establishing what was actually owed doesn't yet exist.

The good news is that this situation is almost entirely avoidable.

Whenever possible, use healthcare providers who routinely bill your insurance before requesting payment in full.

If your provider asks you to pay at the time of service, ask whether they can first submit the claim to the Plan.

If that isn't possible, simply pay using your own funds—whether by check, Apple Pay, Zelle, debit card, or your personal credit card.

As an added bonus, if you use your own rewards credit card, you may even earn cash back, travel points, or other rewards while your claim is being processed.

Before leaving the provider's office, request an itemized receipt that includes:

• The provider's name;
• The provider's Tax Identification Number (TIN);
• The applicable American Dental Association (ADA) procedure code(s) (or the equivalent billing codes for other healthcare providers);
• A description of each service performed;
• The charge for each service; and
• Proof that you paid the provider.

Once the Plan has processed the claim and determined your actual out-of-pocket responsibility, simply submit the required documentation to the Fund Office for reimbursement from your HRA.

It may take one additional step, but you'll avoid IRS compliance issues, preserve your HRA debit card privileges, and—depending on how you paid—possibly earn a few airline miles or enough cash back to celebrate making the process look effortless.

A few minutes of conversation at the front desk can save weeks of frustration later.

The HRA debit card isn't designed to predict what you'll owe.

It's designed to pay what you already know you owe.

There's a world of difference between those two ideas—and that's the difference the Internal Revenue Service cares about.

Perfectly fair.

But what is your question?

Listen, no one is suggesting you break up with your dentist.

If you've found someone you trust, who does excellent work, and you'd happily recommend to your friends, that's worth hanging on to.

Good healthcare providers are hard to find.

That said, there are also plenty of excellent dentists—and physicians, surgeons, and other healthcare providers—who routinely submit claims to insurance plans before collecting the final patient balance.

In fact, many participants in this Plan see providers who do exactly that.

The point isn't that your dentist is "wrong."

The point is that every provider has a different billing process, and those processes don't always align with how an HRA debit card is permitted to be used under IRS regulations.

So, you have a choice.

You can continue seeing the dentist you know and trust.

You can ask whether they're willing to submit the claim to the Plan before collecting your final balance.

If not, you can simply pay the bill using your own funds, obtain an itemized receipt, and request reimbursement from your HRA once the claim has been processed.

Or...

You can continue using the HRA debit card before the claim has been adjudicated and hope everything works out.

Hope, however, has never been recognized by the Internal Revenue Service as an acceptable claims administration procedure.

Ultimately, your relationship with your dentist is your decision.

How the Plan administers its HRA is ours.

Those two decisions can coexist quite happily—as long as the HRA is used in accordance with the Plan and IRS rules.

If it isn't, the consequence may be the permanent deactivation of your HRA debit card.

Not because anyone enjoys turning off debit cards.

Believe it or not, there are easier ways to spend an afternoon than explaining why a piece of plastic stopped working.

The reason is much less dramatic:

Rules exist.

The Trustees administer them.

The IRS regulates them.

And apparently, the IRS has this unusual preference that benefit plans actually follow the rules that they created.

Strange concept, we know.

Think of it this way:

The Trustees wrote the playbook.

Federal law and IRS regulations established the boundaries of the playing field.

The Plan has the responsibility to play the game fairly—and within the rules.