Electronic HSA/FSA/HRA payments

Tina 6 years ago in Payments/ERA Modules updated by crystalp 6 years ago 8

Wondering if anyone has come across this scenario.....A client has a primary and secondary insurance. Primary pays and then you bill the secondary insurance. Before the secondary pays, you receive an automatic rollover HSA electronic payment from the clients primary insurance HSA account. Then you receive the payment from the secondary insurance. The automatic HSA rollovers are becoming a pain. Does anyone have any best practices for this or do we just refund the client all of the HSA dollars and wash our hands? I've tried calling 2 different insurance companies and they will not speak or take any information from me. These clients have become aggravated because they don't understand when you try and explain what is happening.

I was told at one time that you refund the HSA if the secondary pays.

It depends if it is actually a Health Savings Account (funded by the client voluntarily) or an insurance plan that incorporates a Health Reimbursement Account (HRA).  The HRA is a form of secondary insurance and must be used before other secondary plans anyway.  We had HRA payments coming in before the secondary ins. had paid (or after!) too.  Finally did some research and determined that it was best to add the "payer" HRA as a sort of placeholder to remind us not to send to MA or other secondary.  Especially with Health Partners, seem to be a number of plans with the HRA built in, so we note that when checking benefits, and add the HP HRA "payer" to those clients.  We don't actually bill to that payer, as it automatically sends payment on the deductible/etc.  I don't know about the HSA payments...we don't run into that as much.

We inform clients that they should have their HSA turn "off" for us, so that the secondary will be billed. They need to contact their HR person, in order to suspend the HSA for our services. That way, you don't have the issue of having to refund the HSA.

We have had this issue as well. It's complicated. After reading up on some things, I found that HRAs are considered a payer before Medicaid plans. I haven't found good information regarding other secondary insurances that may be commercial plans, but it seems like Marsyl's information is good. HRA's are a part of the insurance plan with that company. I think most payments that come in automatically are HRA's, not HSA's. I guess the fix when a secondary MA/PMAP paid is to void to MA and accept/apply the HRA payment.

The problem is the the claim adj note 187.

Consumer Spending Account payments (includes but is not limited to Flexible
Spending Account, Health Savings Account, Health Reimbursement Account,

How are you supposed to know which is which

Just found this on -line.....

Manage Your HRA Appropriately When You Have Two Commercial Insurances If you have two commercial medical insurances along with a health reimbursement arrangement, both insurance carriers need to process the claim before you can submit any remaining balances to your HRA.

So irregardless if it is HSA, HRA or FSA, both insurance companies need to process the claim before theses funds are used.

Tina, that's good info but it doesn't work for us when the HRA automatically sends payment after the payer associated with that HRA has processed. I've had an HRA one time in my life and after a claim processed the HRA automatically paid it. I did not have to submit anything. I knew I had HRA money but did not have to tell where to send the money. I only had 1 insurance, so it didn't complicate things, but HRA's many times go automatically without the client having to do anything. 

From MHCP provider manual under billing policy, Medicare and other insurance.

Third Party Liability (TPL)

A health reimbursement arrangement (HRA) is considered a group health plan and must be treated as third party liability (TPL). Members must use funds in the HRA to pay their medical expenses before MHCP pays claims.

TPL coverage, including Veterans benefits, private accident insurance and other health care coverage held by or on behalf of an MHCP member, is primary to MHCP.

Health saving accounts (HSA) are considered the member’s personal funds and are not treated as third party liability. An HSA is secondary to MHCP.

Flexible spending accounts (FSA) are not treated as third party libility (TPL).

Follow specific plan coverage rules and policies. A member with more than one level of private benefits must receive care at the highest level available. MHCP will not pay for services that could have been covered by the TPL payer if the applicable rules of that plan had been followed.

If a member fails to complete forms and cooperate in the TPL billing process, contact the worker at the local human service agency (DHS-0005) (PDF) or a MinnesotaCare representative to request help.

Bill TPL payers and receive payment to the fullest extent possible before billing MHCP.