Short answer: Yes. In almost all cases employees must submit a receipt or Explanation of Benefits so the employer or TPA can confirm the expense is qualified under IRC §213(d) before reimbursing, even when a debit card is used.
Yes. In almost all cases, employees must submit receipts or other documentation to be reimbursed from a Health Reimbursement Arrangement (HRA). These plans are employer-funded and tax-advantaged, so the IRS requires proof that each expense is qualified under Section 213(d) of the tax code.
The employer, or a third-party administrator (TPA) hired by the employer, is responsible for reviewing and approving claims before reimbursement can be issued.
What Documentation Is Required?
To be reimbursed, employees must typically submit:
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A detailed receipt or Explanation of Benefits (EOB) showing:
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Date of service or purchase
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Name of the provider or merchant
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Description of the product or service
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Name of the person receiving care (if applicable)
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Amount paid
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Credit card statements or canceled checks are not sufficient; they don’t show what was actually purchased.
How the Process Works:
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Employee incurs an eligible expense and pays out of pocket.
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Employee submits a claim through the HRA portal, app, or paper form, attaching required documentation.
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Administrator reviews the claim for eligibility.
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Reimbursement is issued, often through direct deposit or a mailed check.
Some HRAs may offer a debit card, but even then, documentation is usually required for substantiation unless the system auto-verifies the expense at the point of sale.
Tip for Employers:
Using a reputable TPA can help ensure IRS compliance and reduce the administrative burden of reviewing and storing receipts. The employer remains legally responsible for ensuring all reimbursements are valid.