Tony Novak profile picture
  "AskTony" column archive        


Most Popular

AskTony Archive

This Web site contains a compilation of more than a thousand consumer finance  columns written by Tony Novak from the 1980s through 2006, updated and reformatted for maximum usefulness today.  New material was added after 2010.

Content is the opinion of the author and does not represent the position of any other person or entity. Information is from sources believed to be reliable but cannot be guaranteed.

The author is paid for product endorsements and has an ownership or other financial interest in the businesses related to the topics covered.

New questions

Submit consumer finance questions at and health insurance questions at

Sponsored by: Insurance Exchange - your source of valuable information on state and federal health reform benefits.

Core Health Insurance - America's favorite mini-med insurance  with affordable premiums, freedom to choose providers, optional PPO discounts and guaranteed eligibility regardless of medical conditions.

Please support the Web sites that make publication of AskTony services possible.

HRA plan tax on reimbursement

originally posted: 11/22/2006  reposted: 2/18/2011 This post has not been recently reviewed or revised by the author and may be out of date. If you notice an error or are in doubt, please send a new question by email or ask for an update. Email

Q: If an HRA plan had mistakenly over-reimbursed an employee, is that amount reportable as income to the employee's W-2? And does the plan document have to have some language to disclose that so employees may know that if they get amount in excess of what is qualified medical expenses reimbursement, the excess amount is subject to income tax ?

A: Any money paid to an employee that is not otherwise accounted for as another type of expense is presumed to be wages and subject to wage taxes. On the other hand, an errant over-remimbursement that is timely returned to the employer would not be wages. There are no specific requirements for an HRA plan document contents but most plan documents (or more likely the Summary Plan Description that is distributed to employees) would contain this explanation. The small business HRA plans from Freedom Benefits contain a section explaining these tax consequences and how to get additional help if necessary. IRS uses tough and scary language to describe the adverse tax effects (including penalties for underpayment of wage tax withholding) for failing to timely account for HRA plan disbursements. The Treasury Department is primarily concerned with the large scale use of employer-provided health debit cards by employees without proper documentation as to how the funds are spent. This is not the issue you are posing, so a simple correction should be sufficient.


More resources:

Freedom Benefits Small Business Health Reimbursement Accounts