Limited-scope Health FSA or Limited-scope HRA – Claims Substantiation is Important

If you sponsor a limited scope health FSA or limited scope HRA that covers post-deductible expenses, the claims substantiation rules require independent third party substantiation.  The substantiation incudes demonstrating that the individual whose expense is submitted for reimbursement has satisfied the deductible.  This could be satisfied through submission of an Explanation of Benefits (EOB) showing satisfaction of the applicable deductible.  A  mere statement by the participant that he/she has satisfied the deductible is not sufficient.

If you have any questions or would like additional information, please contact us.