Are medical expenses incurred prior to establishing a BASE HRA eligible for reimbursement?
Medical expenses (including health insurance premiums) incurred prior to your enrollment in an HRA are not eligible for reimbursement. Only those expenses incurred after you establish a plan can be included. BASE® allows reimbursement of expenses to begin on the first day of the month of your enrollment. For example, if you enroll in the BASE® HRA on June 15, then only your expenses established on or after June 1, of that same year are eligible for reimbursement. The IRS reiterated this position in a document published in March 1999 titled “Retroactivity”. The IRS also issued Revenue Ruling 2002-58 to address issues caused by some plans that were still out of compliance.
