Zane Benefits Publishes New Information on 90 Day Waiting Period Rule for HRA Plans

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Under PHS Act Section 2708, Eligibility Conditions Based Solely on the Lapse of a Time Period are Permissible for No More than 90 Days

Today, Zane Benefits, Inc. published new information on HRAs and the 90 day waiting period rule. Zane Benefits, which provides comprehensive and flexible alternatives to traditional employer sponsored health benefits, is the leader in defined contribution and health reimbursement arrangements.

According to Zane Benefits’ website, under new health care reform a Health Reimbursement Arrangement (HRA) may not impose a waiting period that exceeds 90 days effective January 1, 2014.

What is an HRA Plan?

According to Zane Benefits’ website, an HRA Plan is an IRS-approved employer health benefit plan where an employer reimburses an employee for health insurance premiums and out-of-pocket medical expenses such as doctor visits and prescription drugs. An HRA plan is not health insurance.

What is a waiting period?

According to Zane Benefits’ website, under existing law, the term waiting period means "the period that must pass ... before the individual [who is a potential participant or beneficiary] is eligible to be covered for benefits under the terms of the plan."

Generally, a waiting period is the period of time that must pass before a newly hired employee who is otherwise eligible for the HRA plan can become effective. Being eligible for HRA coverage means having met the plan’s eligibility conditions (such as being in an eligible job classification).

What does the 90 day waiting period rule mean for HRA Plans?

According to Zane Benefits’ website, starting January 1, 2014, under PHS Act Section 2708, eligibility conditions that are based solely on the lapse of a time period are permissible for no more than 90 days. Other conditions for eligibility under the terms of a HRA plan are generally permissible, unless the condition is designed to avoid compliance with the 90-day waiting period limitation.

If, under the terms of an HRA plan, an employee may elect coverage that would begin on a date that does not exceed the 90-day waiting period limitation, the 90-day waiting period limitation is considered satisfied. Thus, a HRA plan will not be considered to have violated PHS Act section 2708 merely because employees take additional time to elect coverage.

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About Zane Benefits
Zane Benefits was founded in 2006 to provide a revolutionized SaaS (Software-as-a-Service) administration platform ("ZaneHRA") for Health Reimbursement Arrangements (HRAs) and defined contribution healthcare. The flagship software provides a 100% paperless administration experience to employers and insurance professionals that want to offer better health benefits without a traditional group health insurance plan at lower costs. For more information about ZaneHRA, visit

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Christina Merhar
Zane Benefits
800-391-9209 6725
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