How do health reimbursement arrangements (HRAs) work with flexible spending accounts (FSAs)?

How do HRAs work with FSAs? A medical care expense may not be reimbursed from a health flexible spending arrangement (FSA) if the expense has been reimbursed or is reimbursable under any other accident or health plan coverage is provided under both an HRA and a health FSA for the same medical care expenses, amounts available under an HRA must be exhausted before reimbursements may be made from the FSA. However, a health FSA will not violate this rule if coverage is provided under both an HRA and a health FSA and the FSA reimburses a medical care expense that is not reimbursable by the HRA. In no case may an employee be reimbursed for the same medical care expense by both an HRA and a health FSA.

Before a health FSA plan year begins, the plan document for the HRA may specify that coverage under the HRA is available only after expenses exceeding the dollar amount of the FSA have been paid. For example, if an employer sponsors a health FSA and an HRA, both of which provide coverage for the same medical care expenses, and the HRA plan document includes a provision that the HRA is not available for reimbursements of medical care expenses that are covered by the health FSA until after expenses exceeding the dollar amount of the FSA have been paid, then those medical care expenses may be reimbursed first from the health FSA and then from the HRA when the amount available under the FSA is exhausted.