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.

Which insurance plans are eligible for HRA reimbursement?

Eligible coverage generally includes:

ACA-compliant individual health insurance purchased on or off the Marketplace
Medicare Parts A and B together
Medicare Part C (Medicare Advantage)

Plans that are generally NOT eligible (see also: full eligibility reference above):

Employer-sponsored group health plans (employees cannot participate in both an ICHRA and their employer's group plan)
Short-term health plans (not ACA-compliant)
Dental-only or vision-only plans (these do not satisfy the individual coverage requirement for ICHRA; however, dental and vision premiums may be reimbursable as standalone expenses depending on your plan design)
COBRA continuation coverage is generally not eligible for ICHRA reimbursement unless you are transitioning between plans

If you are unsure whether a specific plan qualifies — particularly Medicare Advantage, Medigap (Medicare Supplement), or off-exchange plans — contact Customer Experience. Eligibility determinations for non-standard plans may require specialist review.

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
Resubmitting compliant documentation within 90 days if Proof of Coverage (POC) is denied

Claims cannot be approved until all required documentation is received. Employees have 90 days to resubmit compliant documentation if Proof of Coverage is denied.

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. This also includes the annual PCORI fee — employers sponsoring an ICHRA or QSEHRA must file IRS Form 720 by July 31 each year, reporting and paying the fee for the prior plan year. See 'PCORI Fee: Does it apply to my QSEHRA or ICHRA' and 'How to Calculate, File, and Pay the PCORI Fee' in the Help Center for full filing instructions.
Ensuring accurate and timely updates to employee eligibility and coverage status to avoid compliance issues

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

How does the reimbursement process support compliance?

The reimbursement workflow includes four steps:

Employees submit proof of coverage or eligible expenses.
Take Command reviews documentation for compliance.
Approved reimbursements are included on the employer's monthly reimbursement statement.
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. If an employee is eligible for any day in a month, they qualify for the full reimbursement amount for that month. There is no pro-rating.

What happens to HRA access and claims when an employee is terminated?

When employment ends:

The employer terminates the employee's HRA eligibility in the Admin Portal.
The employee generally retains portal access for up to 90 days to submit eligible expenses incurred while they were covered.
Expenses incurred after the employee's HRA eligibility end date are not eligible for reimbursement, even if submitted during the runout period.
The employer is responsible for reimbursement decisions and any continuation requirements outside of Take Command (such as COBRA continuation).
Employers are not required to reimburse unused HRA credits after the 90-day runout period.

If a terminated employee's portal access has already been revoked and they need to submit remaining eligible claims, contact Customer Experience — they can temporarily reinstate access for claims submission within the runout window. Employers retain access to company documents and reports even after employee portal access ends.

Frequently asked questions about compliance

Where can I find my PCORI covered lives estimate and filing documentation?

Take Command sends your PCORI covered lives estimate and Form 720 instructions each June to your registered account email. You can also find it in the Admin Portal:

Log in to the Admin Portal.
Navigate to the Documents tab.
Apply the plan year filter (e.g., filter on 2025 to find the document for the July 31, 2026 filing).
Download the PCORI estimate document.

If the document does not appear after applying the correct year filter, or if you need a covered-lives count for a specific month (rather than the annual estimate), contact Customer Experience directly — month-specific participant counts must be generated manually.

An auditor is requesting my Summary Plan Document (SPD) or Basic Plan Document. Where is it?

Your plan documents — including the Summary Plan Description (SPD) and Adoption Agreement — are available in the Admin Portal Documents tab. If you do not see them there, or if your auditor requires a specific document format, contact Customer Experience with your company name and a description of what is needed. Include your auditor's deadline so CX can prioritize.

Note: If your portal only shows an Adoption Agreement and not the full SPD, contact CX — they can provide the complete plan document set. Allow 1–2 business days for document delivery when requested by email.

Can COBRA premiums be reimbursed under my ICHRA or QSEHRA?

COBRA continuation coverage is generally not eligible for ICHRA reimbursement (because COBRA is based on a group plan, not individual coverage). For QSEHRA, COBRA may be reimbursable if your plan design permits it and the employee maintains Minimum Essential Coverage — the eligibility depends on your specific QSEHRA plan configuration.

Contact Customer Experience to confirm whether your plan is configured to allow COBRA reimbursements, and to verify whether a specific employee's COBRA coverage qualifies.

How do I verify that a health plan meets ACA compliance requirements before enrolling an employee?

For ICHRA, the employee's coverage must be individual health insurance that qualifies as Minimum Essential Coverage (MEC) and meets ACA standards — this includes plans purchased on or off the ACA Marketplace, Medicare Parts A+B, or Medicare Advantage. It does not include short-term plans, dental-only, or vision-only plans.

If you are unsure whether a specific plan qualifies — particularly for non-standard coverage like Medicare Supplement (Medigap), off-exchange plans, or multi-part Medicare coverage — contact Customer Experience or your account representative before the employee enrolls. Take Command can confirm eligibility, but this requires specialist review for non-standard plans.

How does Take Command handle reimbursements if the employer uses ADP or another external payroll?

Take Command generates a monthly reimbursement report showing each employee's approved reimbursement amount. The employer then uses this report to issue payments through their own payroll system (ADP, Gusto, Paylocity, etc.). Take Command does not issue reimbursement payments directly.

If payments have been issued through external payroll but the portal still shows amounts as 'Outstanding,' this is expected — the portal does not automatically sync with external payroll systems. To mark reimbursements as paid in the portal, contact Customer Experience with the payment date and amounts. Include 'Billing review request' in the subject. To stop future payments when coverage ends, update the coverage end date in the system.

How to handle ineligible or overpaid reimbursements

Employers should reconcile overpaid reimbursements by requesting repayment, adjusting future payroll, or offsetting against future reimbursements. Internal records should reflect corrected amounts.
To prevent ineligible reimbursements, ensure the employee’s coverage status is updated in the system. Employers can request Take Command to update the reimbursement profile and remove POC if necessary.

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.

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. Past premiums already paid are eligible for reimbursement once claims are approved, and reimbursement is not limited to future premiums.

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?