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One free scan finds every outdated or missing driver and matches the right update for your exact hardware.Free scan · exact hardware matchSection 105(b) and a health reimbursement arrangement (HRA) are not competing benefit plans. Section 105(b) is a federal tax exclusion for qualifying employer-paid medical-care reimbursements. An HRA is an employer-funded health benefit arrangement that may receive that tax treatment when it follows the applicable rules. The practical employer question is therefore not “Which one should we choose?” but “Which HRA design, if any, can reimburse the expenses we intend to cover while meeting tax, Affordable Care Act (ACA), notice, eligibility and substantiation requirements?”
This distinction matters because an employee cannot generally receive an unconditional cash payment tax-free merely because an employer calls it an HRA. The payment must be tied to eligible medical care and handled under the arrangement’s terms. HRA rules also differ substantially by type, so the analysis changes for an integrated HRA, an individual coverage HRA (ICHRA), a qualified small employer HRA (QSEHRA) or an excepted benefit HRA.
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What Section 105(b) is—and what it is not
Section 105(b) of the Internal Revenue Code is a tax rule. It excludes from an employee’s gross income amounts received through an employer’s accident or health plan when those amounts reimburse expenses for medical care. The provision does not create a benefit plan, prescribe a contribution formula or tell an employer which workers must be covered.
The Internal Revenue Service (IRS) explains the key boundary in Revenue Ruling 2005-24: “Section 105(b) does not apply to amounts that the taxpayer would be entitled to receive irrespective of whether or not the taxpayer incurs expenses for medical care.” In practical terms, a payment must be contingent on an eligible medical expense. A benefit that an employee can take as cash whether or not the employee has medical bills is not within the Section 105(b) exclusion.
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The medical-care requirement
Eligible expenses are generally those that fit the definition of medical care in Section 213(d), subject to the plan’s written terms and any restrictions that apply to the particular HRA. The employer or its administrator should require reasonable substantiation—such as an expense statement, explanation of benefits or insurance-premium documentation—before approving reimbursement.
Section 105(b) is not a funding source
Section 105(b) does not itself fund an account. It does not establish a balance that rolls over, set an annual dollar limit or determine whether premiums can be reimbursed. Those questions come from the plan document and the rules governing the underlying arrangement.
What an HRA is and how it relates to Section 105(b)
An HRA is an employer-funded health benefit arrangement. Under the conventional tax-favored model described in IRS Notice 2002-45, the employer funds the arrangement, employees do not make salary-reduction contributions to it, and the HRA reimburses Section 213(d) medical expenses up to a stated limit. Properly structured reimbursements are generally excluded from the employee’s income under Section 105(b).
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- Section 105(b): the tax treatment for qualifying medical-care reimbursements.
- HRA: the employer’s plan or arrangement that defines eligibility, funding, expenses, limits and administration.
An HRA can therefore rely on Section 105(b), but “HRA” does not automatically make every payment tax-free. The arrangement must be employer-funded as required for its type, reimburse an eligible expense, follow its written terms and satisfy other applicable tax and health-plan rules.
Section 105(b) versus HRA: the practical differences
| Issue | Section 105(b) | HRA |
|---|---|---|
| What it is | A federal tax exclusion for qualifying medical-care reimbursements | An employer health-benefit arrangement |
| Main question | Does the payment reimburse eligible medical care in a way that satisfies the exclusion? | Which HRA type is being offered, who may participate, what expenses are eligible and which other rules apply? |
| Funding | Not a funding arrangement | Traditional tax-favored HRA funding is solely from the employer; the described model does not use employee salary-reduction contributions |
| Reimbursement boundary | Actual qualifying medical-care expense; no unconditional cash entitlement | Plan terms determine eligible expenses within applicable law, with substantiation required |
| Additional requirements | Tax-exclusion requirements | Potential ACA market reforms, integration rules, employee-class rules, notices, limits, reporting and administration |
For most employer decisions, comparing HRA types is more useful than comparing “Section 105(b)” with “an HRA.” Section 105(b) tells you whether a reimbursement can be excluded from income; the HRA design determines how the benefit operates.
How a tax-free HRA reimbursement is tested
Use this sequence when reviewing a proposed reimbursement:
- Identify the arrangement. Determine whether the plan is an integrated HRA, ICHRA, QSEHRA, excepted benefit HRA or another design. Do not apply a generic HRA rule before identifying the category.
- Confirm employer funding. Traditional tax-favored HRA funding is provided by the employer. Employee salary-reduction contributions are not the funding method described for that model.
- Check the expense. The claim must be for medical care allowed by Section 213(d) and by the plan. A payment unrelated to an incurred medical expense does not qualify merely because money remains available in an HRA.
- Substantiate the claim. Collect documentation showing the service, product or premium, the date and the amount, and confirm that another plan has not already reimbursed it.
- Apply the plan limit. Reimburse only up to the available balance and any annual or statutory limit that applies to the HRA type.
- Check coverage conditions. Some HRAs require enrollment in group coverage, individual coverage or Medicare. Others are available only when the employer does not offer a group health plan.
- Handle tax reporting and notices. Keep records showing eligibility, substantiation and payments, and deliver any required employee notice. The arrangement’s type determines the details.
Skipping the medical-expense connection is the most serious error. An employer cannot preserve tax-free treatment by labeling an unrestricted allowance “reimbursement.”
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Integrated HRA
An integrated HRA is generally paired with other employer-sponsored group health coverage. The HRA and the group plan must be coordinated under applicable ACA market-reform requirements. The exact integration conditions depend on the coverage and the structure, so an employer should review the plan documents rather than assume that any group policy can be paired with any HRA. The IRS discusses ACA employer treatment at Affordable Care Act Tax Provisions for Employers.
Individual coverage HRA (ICHRA)
An ICHRA can be integrated with individual health insurance coverage or Medicare when the applicable conditions are met. It is designed for an employer that wants to reimburse individual coverage rather than provide one group policy, but the arrangement must follow rules on eligible classes, offer structure and affordability. Employees generally must have the required individual coverage or Medicare for the relevant reimbursement period.
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Because an ICHRA is tied to individual coverage, the employer needs a process to verify enrollment and to apply the same offer consistently within each permitted employee class. The IRS HRA overview explains the basic categories and their conditions at Health Reimbursement Arrangements (HRAs).
Qualified small employer HRA (QSEHRA)
A QSEHRA is generally intended for an eligible small employer that is not an applicable large employer and does not offer a group health plan. It must be funded solely by the employer and meet statutory requirements, including a written notice to eligible employees and annual benefit limits. Employees generally need minimum essential coverage to avoid tax consequences on reimbursements.
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Excepted benefit HRA
An excepted benefit HRA is a limited arrangement that can reimburse certain additional medical costs when the employer makes other group health coverage available and satisfies the applicable conditions. The Department of Labor’s ACA Part 72 FAQ states that the annual limit was $2,150 for plan years beginning in 2025. That figure is a 2025 plan-year amount; employers must verify the limit for any other plan year before setting or communicating a benefit.
Can an employer reimburse individual health-insurance premiums?
Sometimes. Premium reimbursement depends on the HRA category and the plan’s terms; it is not a universal feature of every HRA.
- An ICHRA may reimburse premiums for eligible individual health insurance coverage or Medicare when its integration, class and affordability requirements are satisfied.
- A QSEHRA may reimburse eligible individual health-insurance premiums when the small employer meets QSEHRA requirements and the employee has the required coverage.
- An integrated HRA is generally coordinated with group health coverage, so its reimbursement scope depends on the integration design and the underlying group plan.
- An excepted benefit HRA is limited to the expenses allowed by its rules and plan document; it should not be treated as a general premium-reimbursement vehicle.
Before promising premium reimbursement, identify the HRA type, the insurance that qualifies, the employee classes covered, the substantiation method and the effect on affordability or other ACA obligations. The phrase “HRA pays premiums” is too broad to be a reliable plan description.
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Can a small employer offer an HRA instead of group health insurance?
An eligible small employer may be able to use a QSEHRA instead of offering a group health plan. The employer must meet the QSEHRA eligibility rules, fund the benefit itself, observe the annual limits and provide the required notice. The employees’ individual coverage and the interaction with premium tax credits also need to be addressed in the employee communications.
An ICHRA can also be used in a strategy built around individual coverage, but it is a different arrangement with different class, coverage and affordability rules. An employer should not select an ICHRA merely because it wants to avoid a group policy; the offer must be designed and administered according to the ICHRA requirements.
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ACA, employee classes and eligibility considerations
HRAs are generally subject to group-health-plan market reforms unless a specific exception or integration rule applies. The correct analysis depends on the arrangement and the other coverage made available. The IRS’s employer ACA guidance and HRA overview should be read with the plan document and current regulatory guidance.
Employee classes
Some HRA types permit different offers to defined employee classes, while others require more uniform treatment. Classes may be based on factors such as full-time or part-time status, geographic location, seasonal status or collective-bargaining coverage, but the permitted categories and minimum-class rules are technical. An employer should document the class definition before announcing different amounts or coverage options.
Affordability and minimum coverage
For arrangements connected to individual coverage, the amount an employer offers can affect affordability determinations and an employee’s access to other tax benefits. QSEHRA participants generally need minimum essential coverage to receive reimbursements tax-free. A plan administrator should explain how employees verify coverage and what happens when coverage ends midyear.
Notices
Notice deadlines and content vary. QSEHRA employers have a specific employee-notice obligation, while ICHRA and other arrangements have their own disclosure and communication requirements. Keep proof of delivery and use the notice required for the plan type rather than a generic “HRA summary.”
What employers should put in the plan document
A workable document should answer operational questions before the first claim arrives:
- Which employees and dependents are eligible, and when does eligibility begin?
- Which HRA category is being used?
- Which Section 213(d) expenses are reimbursable, and are premiums included?
- Are individual coverage, Medicare or group-coverage conditions required?
- What is the annual or monthly reimbursement limit?
- Does unused credit roll over, and what happens at termination or retirement?
- What documentation must an employee submit?
- Who reviews claims and how are duplicate reimbursements prevented?
- What notices are required, when are they sent and how are changes communicated?
- How are reimbursements reported, and what records must the employer retain?
A plan that leaves these questions open invites inconsistent treatment. The tax exclusion follows the actual operation of the arrangement, not just the title on a benefits spreadsheet.
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Common mistakes and how to correct them
Calling a taxable allowance an HRA
Problem: The employer pays a fixed amount every month whether or not the employee incurs medical expenses.
Correction: Tie payment to substantiated eligible expenses under a written arrangement. If the employer wants a cash allowance instead, obtain tax advice about treating it as taxable compensation rather than describing it as a Section 105(b) reimbursement.
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Assuming every HRA reimburses premiums
Problem: A policy summary says “health costs” without specifying whether premiums qualify.
Correction: State the eligible premium categories and the required coverage for the particular HRA type. Confirm the treatment before employees purchase coverage expecting reimbursement.
Using the wrong annual limit
Problem: A prior-year limit is copied into a new plan year, or a 2025 excepted benefit HRA amount is presented as a 2026 figure.
Correction: Label every limit by plan year. For example, the 2026 QSEHRA maximums are $6,450 self-only and $13,100 family under IRS Publication 15-B, while the $2,150 excepted-benefit figure cited by the Department of Labor applies to plan years beginning in 2025.
Ignoring coverage changes
Problem: An employee loses individual coverage, changes from self-only to family coverage or moves into a different eligibility class, but reimbursements continue unchanged.
Correction: Require employees to report coverage changes and build a periodic verification process into administration.
Failing to substantiate claims
Problem: The employer pays from an available balance without confirming that an expense was incurred and eligible.
Correction: Use a consistent substantiation checklist and retain records showing the expense, amount, date and coverage status where relevant.
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A step-by-step employer decision process
- Define the business objective. Decide whether the goal is to supplement an existing group plan, reimburse individual coverage, support a small workforce without group insurance or cover limited additional expenses.
- Check employer eligibility. Determine whether the employer is an applicable large employer, whether a group plan is offered and whether the workforce includes classes that require separate treatment.
- Select the HRA category. Compare integrated HRA, ICHRA, QSEHRA and excepted benefit HRA requirements instead of treating “HRA” as one product.
- Set the reimbursement scope. List the medical expenses and premiums the plan will reimburse, then test the list against Section 213(d) and the arrangement’s specific rules.
- Set the amount and timing. Establish annual or monthly limits, prorating rules, carryover treatment and termination provisions. Verify current-year statutory limits where they apply.
- Design administration. Choose who will substantiate claims, how employees submit documents, how duplicate claims are prevented and how balances are tracked.
- Prepare notices and employee materials. Explain eligibility, qualifying coverage, reimbursable expenses, documentation and what happens when circumstances change.
- Review tax and ACA consequences. Have qualified benefits and tax professionals review the document, affordability analysis, reporting and interaction with other employer plans.
- Audit operation after launch. Compare paid claims with the plan terms, sample documentation, verify notices and update limits and communications for each new plan year.
Questions employers and employees commonly ask
Is an HRA reimbursement tax-free to the employee?
It can be, when the reimbursement is for an eligible medical-care expense, is paid under a qualifying employer-funded arrangement and satisfies the applicable HRA rules. An unconditional cash amount is not made tax-free simply by being called an HRA payment.
Does Section 105(b) create an HRA?
No. Section 105(b) is the tax-exclusion rule; the HRA is the plan that sets funding, eligibility, expenses, limits and administration.
Can employees contribute money to a traditional HRA?
The conventional tax-favored HRA model described by the IRS is funded solely by the employer, not by employee salary reduction. Other account-based benefits may have different funding rules and should not be conflated with an HRA.
What is the 2026 QSEHRA limit?
IRS Publication 15-B lists $6,450 for self-only expenses and $13,100 for family expenses for 2026. These are annual maximum benefit amounts; the plan may offer less, and partial-year eligibility can require proration.
Is the $2,150 excepted benefit HRA limit a 2026 amount?
No conclusion about 2026 should be drawn from that number. The Department of Labor cites $2,150 for plan years beginning in 2025. Verify the applicable amount for the plan year being designed.
Can an employer reimburse any medical bill tax-free?
No. The expense must fit the applicable medical-care definition and the written plan, be properly substantiated and fall within the arrangement’s limits and coverage conditions.
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Where to verify current requirements
Federal rules and annual limits can change. Employers should review the current IRS HRA overview, IRS Notice 2002-45, Revenue Ruling 2005-24, IRS ACA employer guidance, Publication 15-B for 2026 and the Department of Labor’s Part 72 FAQ. Those materials provide general U.S. federal guidance, not an individualized determination. The employer’s plan administrator and qualified benefits and tax professionals should confirm the final design, notices, substantiation process and current-year limits.
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