Q.- Can an HRA allow the reimbursement of an expense incurred in a prior year to be reimbursed from the present plan year’s account?
A.- A plan could be structured to allow the reimbursement of a qualified medical expense from a prior plan year, so long as the employee was participating in the HRA when the expense was incurred. According to IRS Notice 2002-45- “Although claims incurred during one coverage period may be reimbursed in a later coverage period, an unreimbursed claim may be reimbursed in a later coverage period only if the individual was covered under the HRA when the claim was incurred.”
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