“We have an HRA” is about as precise as “we have a vehicle.” Could be a bicycle. Could be a forklift.
Three types employers actually mean
Excepted benefit HRA — sits beside a traditional group medical plan, limited in amount, used for extras (copays, dental/vision premiums in some designs, etc.). For plan years beginning in 2026, the maximum amount that may be newly available is $2,200.
ICHRA (Individual Coverage HRA) — employer reimburses individual-market premiums (and often other medical expenses) in lieu of (or class-by-class alongside) group coverage. Notice timing and class design rules are the compliance guts.
QSEHRA — for qualifying small employers that don’t offer group coverage; statutory caps and notice rules differ from ICHRA.
Why the distinctions matter to a TPA
Reimbursement substantiation, COBRA treatment, PCORI exposure, and employee notice content all change with the HRA flavor. Mixing ICHRA talking points with excepted-benefit HRA limits is how employers accidentally overshare the wrong promise.
March action item
Label your plans the way counsel and your administrator label them — in the SPD, the employee FAQ, and the broker one-pager. If those three documents disagree, participants will believe whichever one reimburses faster.