Forms

HSA/HRA Reimbursement Changes

In March, President Obama signed the Patient Protection and
Affordable Care Act and the Health Care and Education
Reconciliation Act of 2010 (collectively “the Act”). The Act
includes a number of modifications to employee benefit
programs. One provision that will affect employee participants
beginning January 1, 2011 is the requirement that over-the-
counter (OTC) drugs, medicines, and biologicals must be
accompanied by a physician’s prescription in order to be
reimbursed under a Health Savings Account (HSA) or Health
Reimbursement Arrangement (HRA) account. Below is a
summary of how this change will
impact HDHP members.

Under the Act, OTC drugs, medicines, and biologicals will
continue to be eligible for reimbursement as long as the request
is accompanied by a doctor’s prescription. This means items
such as cough medicines, pain relievers, acid controllers, and
diaper rash ointment will now require a doctor’s prescription to
be submitted along with the reimbursement request. Insulin and
other OTC items, such as band-aids, will continue to be eligible
without a prescription.

Since this change applies to all expenses incurred on or after
January 1, 2011 it will affect all plans and participants at the
same time, regardless of the plan year. OTC drug expenses
incurred on or after January 1, 2011 will require a doctor’s
prescription in order to be reimbursed under a HSA or HRA;
expenses incurred prior to January 1, 2011 will not.

For example, for a calendar year plan with a claim-it-by date of
March 31, 2011, an OTC drug purchased on December 31, 2010
could be submitted before a plan’s claim-it-by date of March 31,
2011 and still be reimbursed without a prescription.

This provision will also impact the use of all heath care debit
cards. Beginning January 1, 2011, merchants who are
IIAS certified will need to modify the list of items eligible for
payment. The list will be shorter; this is because of the doctor’s
prescription requirement. With the shorter list, fewer purchases
will be authorized and auto substantiated at the point-of-sale.
Purchases of OTC drugs, medicines, and biologicals will
require another form of payment and then the employee can
submit a claim or request for reimbursement along with the
doctor’s prescription for the OTC drug, medicine, or biological
purchased.

This change affects only OTC drugs, medicines, and biologicals
- bandages, home health-aids, and other OTC items will still be
eligible and can be purchased using the card without further
documentation.

The following are examples of items that will require a doctor’s
prescription and cannot be purchased using a health care debit
card:

Acid Controllers
Allergy & Sinus Medications
Antibiotic Products
Anti-Diarrhea Medications
Anti-Gas
Anti-Itch & Insect Bite Ointments
Anti-Parasitic Treatments
Baby Rash Ointments/Creams
Cold Sore Remedies
Cough, Cold & Flu
Digestive Aids
Feminine Anti-Fungal/Anti-Itch
Hemorrhoid Preps
Laxatives
Motion Sickness Remedies
Pain Relievers
Respiratory Treatments
Sleep Aids & Sedatives
Stomach Discomfort Remedies

The following are examples of some of the OTC items that will
remain available without a doctor’s prescription and may be
purchased with a health debit card: