Short answer: It depends on the HRA’s structure. SBCs are not required for standalone HRAs, but if an HRA is integrated with a group health plan, the plan’s SBC must reflect the HRA’s impact on coverage and cost-sharing.
Whether a Summary of Benefits and Coverage (SBC) is required for a Health Reimbursement Arrangement depends on whether the HRA stands alone or is integrated with a group medical plan.
A standalone HRA, meaning an arrangement that provides benefits independent of a group medical plan, generally does not require its own SBC. These arrangements are uncommon because most standalone HRAs do not satisfy Affordable Care Act market reforms on their own.
When an HRA is integrated with a group health plan, which is the more typical structure, the SBC for the group medical plan must account for the HRA’s effect on benefits and cost-sharing. For example, if the HRA reimburses a portion of the deductible or other out-of-pocket costs, the SBC should reflect how that reimbursement changes what the employee ultimately pays.
Individual Coverage HRAs (ICHRAs) and Qualified Small Employer HRAs (QSEHRAs) are not subject to traditional SBC requirements. Instead, they are governed by separate federal notice rules that require specific disclosures to employees at set times.
SBC obligations depend on whether the arrangement is treated as part of a group health plan and how benefits are coordinated, rather than on the HRA label alone.
Sources
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Centers for Medicare & Medicaid Services, Summary of Benefits and Coverage (SBC)
https://www.cms.gov/cciio/resources/forms-reports-and-other-resources/summary-of-benefits-and-coverage -
U.S. Department of Labor, HRAs and SBC Requirements
https://www.dol.gov/agencies/ebsa/laws-and-regulations/laws/affordable-care-act/for-employers-and-advisers -
29 CFR §2590.715-2715
Content history
Originally published: June 16, 2025
Last reviewed: January 25, 2026