There are four types
of tax-advantaged accounts that can be used to pay for unreimbursed medical
expenses: (1) Health Care Flexible Spending Accounts (FSAs), (2) Health
Reimbursement Accounts (HRAs), (3) Health Savings Accounts (HSAs), and (4)
Archer Medical Savings Accounts (MSAs).
Comparison of the four
types of accounts
FSAs. These are
employer-established arrangements that are usually funded through salary
reduction agreements. The employee's contribution isn't
subject to either income or employment taxes. Under the ACA, beginning in 2013,
FSA contributions are limited to $2,500 per employee.
HRAs. These are
employer-established arrangements that are funded only through employer
contributions. HRA contributions are not subject to either income or employment
taxes and health care benefits used for medical care are
tax exempt.
HRAs are group health
plans that typically consist of a promise by an employer to reimburse medical
expenses for a year up to a certain amount,
with unused amounts available to reimburse medical expenses in future years.
That causes a problem under Sec. 2711 of the Public Health Service Act (PHSA),
as added by the ACA, which generally prohibits plans and issuers from imposing
lifetime or annual limits on the dollar value of essential health benefits. IRS
has ruled that HRAs are permitted when they are integrated with other
employer-provided coverage, and are not permitted when they are stand-alone
accounts.
HSAs. These are
tax-exempt accounts that can be established (and to which
contributions can be made) only when the account owner has a qualifying high
deductible health insurance plan (HDHP). For example, for 2013 as well as 2014,
the plan must have a deductible of at least $1,250 for self-only coverage and
$2,500 for family coverage.
For 2013, annual
out-of-pocket expenses (deductibles, co-pays, and other amounts, but not
premiums) can't exceed $6,250 for self-only coverage or $12,500 for family
coverage (for 2014, $6,350 and $12,700 respectively). The plan holder may have
no other major medical health insurance policy. Contributions made by employers
are exempt from income and employment taxes, and account owners may deduct
contributions they make. Withdrawals for medical expenses are not taxed. Unused balances may
be carried over from year to year. Contributions for 2013 are
limited to $3,250 for self-only coverage and $6,450 for family coverage (for
2014, $3,300 and $6,550 respectively). An additional contribution of $1,000 is
allowed to people age 55 and older.
MSAs. These accounts,
also known as Archer MSAs, are earlier versions of HSAs and are in limited use
under current law. MSAs can be established generally only
when account owners have qualifying high deductible insurance and no other coverage.
Contributions made by employers are exempt from income and employment taxes,
and contributions by account owners (which are allowed only if the employer
doesn't contribute) are deductible. Withdrawals are not taxed if used for
medical expenses. Unused balances may be carried over from year to year
without limit.
The principal
difference between HSAs and MSAs is that MSA eligibility is limited to people
who are self-employed or employed by a small employer (50 or fewer employees,
on average). In addition, the MSA minimum deductible levels are higher and the
contribution limits are lower. Generally, no MSAs can be created after
Dec. 31, 2007, although MSAs existing at that time are grandfathered.
National statistics
40% of all civilian workers in 2012 had access
to a health care FSA. When viewed by firm size, 53% of civilian workers in
firms with 100 or more workers had access to an FSA. In establishments with
fewer than 100 employees, 20% of the workers had access to a health care FSA.
HSAs are only available to employees who have
HDHPs. In 2012, 26% of firms offering health benefits offered an HSA-qualified
HDHP (up from 18% in 2011 and 12% in 2010). Workers in larger firms were more
likely to have access to an HDHP than those in smaller firms.
Although employers are not required to
restrict HRA benefits to employees with HDHPs, most employers chose to do so.
Of employers offering health benefits, there was no discernible upward or
downward trend in the percent who offered an HDHP and an HRA in recent years;
the percentage was 4% in 2010, 7% in 2011, and 5% in 2012.
The CRS report says
that almost no data is available on usage of MSAs, as very few new MSAs are
being created, and the number of them always has been limited.
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