Health Reimbursement Account (HRA)

The HRA is the least-understood of the three major tax-advantaged health accounts in U.S. employment. It's often confused with the FSA (which is employee-funded) and the HSA (which is employee-owned). The HRA is entirely different: the employer funds it, the employer owns it, and the employer sets the rules within IRS and ACA limits. Over the last decade the HRA has become a more strategic tool than a supplemental one, especially with the introduction of the Individual Coverage HRA (ICHRA) in 2020, which allows employers to offer HRA-funded reimbursement for individually purchased coverage rather than sponsoring a group plan at all. IRS data shows HRA-based plans are the fastest-growing segment of the commercial benefits market.

What an HRA Actually Is

An HRA is a notional account, not a bank account. The employer credits it with an annual amount, and employees submit qualified medical expenses for tax-free reimbursement up to the available balance. Unused funds can roll over year to year (at the employer's option), but if the employee leaves, the unused funds return to the employer. The reimbursement flows through payroll or a third-party administrator.

The key tax feature is that reimbursements are excluded from federal income tax and FICA for both the employee and the employer, making the HRA roughly as tax-efficient as an FSA for the employee and more tax-efficient for the employer (because the employer also saves on its FICA match).

How Is an HRA Different From an FSA and an HSA?

An FSA is funded by employee pre-tax contributions and is use-it-or-lose-it with limited carryover. An HSA is individually owned, portable, and rolls over indefinitely, but requires a high-deductible health plan. An HRA is employer-funded, employer-owned, non-portable, and flexible in design. The employer picks which expenses are eligible and whether unused funds carry over.

The Main HRA Variants in 2026

Traditional HRAs pair with a group health plan and reimburse copays, coinsurance, deductibles, or other qualified expenses the group plan doesn't cover. ICHRAs reimburse employees for individual-market health insurance premiums plus qualified expenses, instead of offering a group plan. QSEHRAs are limited to small employers (under 50 employees) that don't offer a group plan and allow capped tax-free reimbursement for individual coverage and expenses.

Excepted Benefit HRAs reimburse limited categories of expenses (like dental, vision, COBRA premiums) and can be offered alongside a group plan with $2,100 annual limit for 2026.

Why ICHRAs Are the Growth Story

The ICHRA has been growing by roughly 40-50% per year in new adoption since 2022 according to HRA administrators. It appeals to two specific employer profiles. Small employers who can't sustain group plan economics but want to offer a tax-advantaged benefit. And distributed-workforce employers with employees in many states who find group-plan network matching impractical.

The ICHRA mechanics require careful compliance: class-based offer structures, affordability calculations tied to the ACA employer mandate, and notice requirements that must be delivered in specific formats. The IRS and DOL Publication 15-B and the final ICHRA regulations are the primary references.

Choosing How HRAs Fit Into Your Benefits Strategy

The HRA decision is about what problem you're trying to solve. If employees need help with first-dollar costs on a high-deductible plan, a traditional HRA or an HSA-compatible HRA fits well. If you want to exit group health sponsorship without dropping benefits, an ICHRA is the cleanest path. If you're a small employer starting a benefits program, a QSEHRA can be a tax-advantaged alternative to raising wages. Whichever structure fits, plan document drafting, administrator selection, and clear onboarding communications are what determine whether employees actually use the benefit. Under-utilized HRAs are a common failure mode, and the cause is almost always poor communication rather than plan design. Set the expectation clearly at enrollment, send mid-year balance reminders, and track utilization the same way you track other benefits engagement.