An HRA offered alongside, or integrated with, an HDHP will generally be structured in one of three ways:

• General-purpose HRA: Available to reimburse qualifying medical expenses up to a certain annual dollar limit at any time during the plan year.
• Post-deductible HRA: Reimbursements not available until after a participant incurs claims up to a set dollar amount, and thereafter available to reimburse qualifying medical expenses up to a certain annual dollar limit.
• Limited-purpose HRA: Reimbursements immediately available, but only for limited-scope dental and vision expenses up to a certain annual dollar limit.

A general-purpose HRA offering will make all participants ineligible to contribute to an HSA. Being eligible for HRA reimbursement prior to incurring claims of at least $1,700 for single HDHP coverage, or $3,400 for family HDHP coverage (in 2026) is disqualifying coverage for purposes of HSA-eligibility. This is true regardless of whether the participants actually receive any reimbursement from the HRA.

However, a post-deductible HRA or limited-purpose HRA will not interfere with HSA eligibility. A post-deductible HRA paired with an HDHP allows for HSA-eligibility so long as the HRA doesn’t provide coverage before the individual incurs claims of at least $1,700 for single or $3,400 for family coverage (in 2026). In addition, a limited-purpose HRA (available solely to reimburse dental or vision expenses) paired with an HDHP also allows participants to be eligible to make and receive HSA contributions.听

Finally, a combination of limited-purpose and post-deductible HRAs paired with an HDHP will also allow for HSA-eligibility. For example, the HRA could provide limited-purpose reimbursement (solely for dental or vision expenses) until the minimum HDHP deductible is met ($1,700 for single; $3,400 for family in 2026) and then become available to reimburse all qualifying medical expenses once the deductible is met. This is confirmed in .

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This blog post was recently updated in April 2026.

he information in this blog post is for educational purposes only. It is not legal or tax advice. For legal or tax advice, you should consult your own legal counsel, tax and investment advisers.听

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Further, if the employee is enrolled in family HDHP coverage, the employee may contribute up to the family annual contribution limit, even if some individuals enrolled in the coverage are ineligible. See the excerpt from .

How do the maximum annual HSA contribution limits apply to an eligible individual with family HDHP coverage for the entire year if the family HDHP covers spouses or dependent children who also have coverage by a non-HDHP, Medicare, or Medicaid?

The eligible individual may contribute the 搂 223(b)(2)(B) statutory maximum for family coverage. Other coverage of dependent children or spouses does not affect the individual鈥檚 contribution limit, except that if the spouse is not an otherwise eligible individual, no part of the HSA contribution can be allocated to the spouse.

In the answer, the IRS recognizes that normally the family HDHP annual contribution limit can be split between the spouses if they are both HSA-eligible, allowing each of them to open separate HSAs and contribute so long as together they do not contribute in excess of the annual contribution limit. However, if one of the spouses has disqualifying coverage, that spouse cannot contribute to their own HSA; rather, only the eligible spouse may contribute to an HSA and then can contribute up to the full family maximum since they don鈥檛 have to split it with the other spouse.

And finally, keep in mind that once funds are contributed to the HSA, the funds can be used to reimburse qualifying medical expenses for the HSA account holder and the account holder鈥檚 spouse and tax dependents. The spouse鈥檚 and dependents鈥� qualifying medical expenses would continue to be eligible for reimbursement from the employee鈥檚 HSA even if the spouse or dependents are not HSA-eligible.

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The permitted election change events that apply to dependent care FSAs fall into the following broad categories:听

• Change in status. For dependent care FSA purposes, various changes in status such as changes to the employee鈥檚 work schedule, an employee鈥檚 divorce, and others may affect eligibility for dependent care expenses.
• Change in cost or coverage. Under these rules, certain changes in the cost or coverage of the dependent care FSA will justify a mid-year election change. For example, when there is a change in the cost of a dependent care provider, a plan may permit a mid-year election change.
• FMLA. Employees who take FMLA leave are entitled to revoke elections of non-health benefits (such as a dependent care FSA) under a cafeteria plan to the same extent as employees taking non-FMLA leave. And certain reinstatement rules apply on return from FMLA leave.

The flexibility for dependent care FSA changes mid-plan year is best illustrated by the examples found in Under dependent care FSA election change rules, a change in the employee鈥檚 or spouse鈥檚 work schedule, a change in provider, a change in provider availability, a change in daycare due to change in school schedule, etc., would all likely permit a mid-year change in dependent care FSA elections. 

Remember that, like all election changes, some of these are permitted but not required by IRS rules. Therefore, it will always be necessary to review the terms of the employer鈥檚 cafeteria plan document to confirm whether a particular change is allowed.

Content for the 糖心Vlogcompliance Q&A is provided by . Benefit Comply provides employee benefits compliance support and services to brokers, employee benefits consultants, and TPAs nationwide. For more information go to .

The information in this blog post is for educational purposes only. It is not legal or tax advice. For legal or tax advice, you should consult your own legal counsel, tax and investment advisers. 

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For purposes of eligibility for a premium tax credit toward coverage through a public Marketplace: 

• Coverage is generally considered 鈥渁ffordable鈥� for the employee if the employee contribution for employee-only (single) coverage does not exceed a set percentage (8.39% in 2024) of household income.  
• Effective January 1, 2023, coverage is considered 鈥渁ffordable鈥� for family members if the employee contribution for the family to participate in the employer-sponsored plan does not exceed a set percentage (8.39% in 2024) of household income.  

Each year, the IRS adjusts the percentage used to determine affordability. The percentage can go up or down from one year to the next, potentially requiring employers to adjust employee contributions to meet affordability each year. The affordability percentage applies based on plan year, allowing employers with non-calendar year plans to adjust employee contributions upon plan renewal rather than having to make adjustments each January. For example, the 8.39% for 2024 for a September through August plan year would have to use 8.39% to calculate affordability beginning in September 2024.  

An ALE will meet 搂4980H(b) requirements if the employee contribution for employee-only (single) coverage is affordable; there is no requirement for an employer to make coverage affordable for family members. In addition, even if single coverage is unaffordable for an employee based on their personal household income, coverage is considered 鈥渁ffordable鈥� under 搂4980H(b) requirements if the employee contribution satisfies at least one of three available safe harbors (i.e., Federal Poverty Level (FPL), Rate of Pay, or Form W-2). 

Employers may use any of the three affordability safe harbors for any reasonable category of employees, provided the same safe harbor is used on a uniform and consistent basis for all employees in a category. The regulations provide that reasonable categories for this purpose generally include specified job categories, nature of compensation (hourly or salary), geographic location, and similar bona fide business criteria. The following are the three available affordability safe harbors:

• FPL – Employee contribution does not exceed 8.39% (in 2024) of FPL for a single individual.
• Rate of Pay – Employee contribution does not exceed 8.39% (in 2024) of hourly rate x 130 (or monthly salary).
• Form W-2 – Employee contribution does not exceed 8.39% (in 2024) of 2024 Box 1 wages.

TIP: When determining which affordability safe harbor to use, employers should first consider the FPL safe harbor because it is the simplest and guarantees affordability for all employees. If the monthly employee contribution for single coverage does not meet the FPL safe harbor, then the employer should consider the rate of pay or Form W-2 safe harbor which will often allow for a larger employee contribution to be deemed affordable depending on employee compensation levels.

Content for the 糖心Vlogcompliance Q&A is provided by . Benefit Comply provides employee benefits compliance support and services to brokers, employee benefits consultants, and TPAs nationwide. For more information go to .

The information in this blog post is for educational purposes only. It is not legal or tax advice. For legal or tax advice, you should consult your own legal counsel, tax and investment advisers. 

糖心Vlogreceives compensation from some of the merchants identified in its blog posts. By linking to these products, 糖心Vlogis not endorsing these products.

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