HRA in one paragraph
An HRA (Health Reimbursement Arrangement) is an employer-funded account that reimburses employees for medical expenses. The employer commits a dollar amount; employees draw against it for qualifying costs. HRAs are funded entirely by the employer (no employee pre-tax contribution). They reduce the employer's wage cost but not the FICA tax base on the employee's payroll line.
SIMERP in one paragraph
A SIMERP also reimburses employees for medical expenses, but the funding mechanism is different: it includes an employee pre-tax election under Section 125. That pre-tax election lowers the wage base on both sides of the FICA line. The employer's contribution is to plan administration, not to a per-employee benefit pot.
Why this matters for the employer
An HRA reduces employer benefit cost outflows but doesn't reduce payroll tax. A SIMERP reduces payroll tax (FICA on both sides of the line) and provides reimbursement-based benefits to the employee. They're not substitutes; many employers run both.
The compliance differences
- HRAs are governed primarily under Section 105 and the ACA's integration rules.
- SIMERPs are governed under Section 125 + Section 105(b) + Section 213(d), with ERISA and HIPAA layered on top.
- Both require formal plan documents and SPDs.
- The IRS Chief Counsel Memorandum on indemnity wellness plans does not apply to either properly structured HRAs or SIMERPs - it applies to indemnity-style cash-payment plans dressed up as health benefits.