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HRA Compliance: How Take Command Supports Compliance for ICHRA and QSEHRA

This article is for employers and employees using Take Command to administer an Individual Coverage HRA (ICHRA) or Qualified Small Employer HRA (QSEHRA).

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Written by Mel Vazquez-Martinez

Take Command helps employers administer compliant HRAs by reviewing documentation, verifying eligibility, generating required plan documents, and providing reimbursement reports. Employers remain responsible for funding and issuing reimbursement payments.

Note: If you are experiencing portal access issues — such as missing menu sections, inability to upload documents, or features not working as expected — contact Customer Experience or see the portal troubleshooting guides. This article covers HRA compliance requirements, not portal navigation.

What does HRA compliance mean?

HRA compliance means reimbursements meet IRS and applicable federal requirements, including:

  • Employees have eligible health coverage when required

  • Reimbursements are supported by proper documentation

  • Only eligible premiums and qualified medical expenses are reimbursed

  • Reimbursements receive the correct tax treatment

  • Required employer reporting is completed

Maintaining compliance helps preserve the tax-free status of HRA reimbursements.


How does Take Command support compliance?

Take Command helps employers administer compliant HRAs by:

  • Generating required plan documents, including Summary Plan Descriptions (SPDs)

  • Reviewing proof of coverage for eligibility

  • Verifying submitted reimbursement claims before approval

  • Monitoring ongoing employee eligibility

  • Providing monthly reimbursement reports

  • Supporting employers with compliance questions and regulatory updates

Take Command administers the HRA, but employers are responsible for funding reimbursements.


What are employee responsibilities?

Employees are responsible for:

  • Enrolling in eligible individual health insurance or qualifying Medicare coverage

  • Maintaining eligible coverage while participating in the HRA

  • Uploading required proof of coverage

  • Submitting eligible premium or medical expense documentation for reimbursement

Claims cannot be approved until all required documentation is received.


What are employer responsibilities?

Employers are responsible for:

  • Funding the HRA benefit

  • Reviewing monthly reimbursement statements

  • Issuing reimbursement payments

  • Maintaining plan design and eligibility rules

  • Completing required tax reporting, including QSEHRA W-2 reporting when applicable

Take Command approves eligible claims but does not issue reimbursement payments.


How does the reimbursement process support compliance?

The reimbursement workflow includes four steps:

  1. Employees submit proof of coverage or eligible expenses.

  2. Take Command reviews documentation for compliance.

  3. Approved reimbursements are included on the employer's monthly reimbursement statement.

  4. The employer issues reimbursement payments.

This review process helps ensure only eligible reimbursements are approved. Reimbursement reports are generated on a monthly cycle. If you have questions about specific payment timing, contact your employer — they determine when approved reimbursements are issued.


What documentation is required?

Employees may be asked to provide documentation such as:

  • Proof of individual health insurance coverage

  • Medicare enrollment documentation (when applicable)

  • Premium invoices or payment receipts

  • Receipts for qualified medical expenses

Documentation must clearly identify the covered individual, coverage or expense, applicable dates, and payment amount when required.


What coverage is eligible?

Eligible coverage generally includes:

  • ACA-compliant individual health insurance

  • Medicare Parts A and B together

  • Medicare Part C (Medicare Advantage)

Coverage that does not meet HRA eligibility requirements cannot be reimbursed.

If you are unsure whether a specific plan qualifies for HRA reimbursement — such as Medicare Advantage, Medigap, or short-term plans — contact Customer Experience. Eligibility determinations for specific plan types may require specialist review.


Can employees purchase coverage outside Take Command?

Yes. Employees may purchase eligible individual health insurance through:

  • Healthcare.gov or a state Marketplace

  • An insurance carrier

  • A licensed insurance broker

  • Take Command

As long as the coverage is eligible under the HRA, reimbursement eligibility is the same regardless of where the policy was purchased.


Does Take Command offer an HRA debit card?

No. Take Command does not provide preloaded HRA or debit cards.

Employees must submit eligible expenses through the platform before reimbursement can be approved.


What if my health plan has a $0 premium?

If your monthly premium is $0:

  • Enter $0 as your premium amount when submitting coverage.

  • You may still submit other eligible medical expenses for reimbursement if your HRA allows them.


Can employers issue retroactive reimbursements?

Yes. Employers may choose to reimburse previously eligible expenses according to their HRA plan rules.

Take Command does not determine whether an employer offers retroactive reimbursements.


What happens if my employer stops using Take Command?

If your employer no longer administers its HRA through Take Command:

  • Future reimbursement administration becomes the employer's responsibility.

  • Contact your HR or benefits administrator for instructions regarding reimbursement requests.


What happens when an employee leaves the company?

When employment ends:

  • Employers remove the employee from the active roster.

  • Employees generally retain portal access for up to 90 days to submit eligible expenses incurred while covered.

  • Employers remain responsible for reimbursement decisions and any continuation requirements outside of Take Command.


Key takeaway

Take Command helps employers maintain HRA compliance by reviewing documentation, verifying eligibility, generating required plan documents, and providing reimbursement reports. Employers remain responsible for funding and issuing reimbursement payments, while employees are responsible for maintaining eligible coverage and submitting accurate documentation.

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