NRECA Employee Benefits Weekly

125 Plan and HRAs: Documents for 2025 Plan Year Are Available Online

Posted on Posted in Tax-advantaged Accounts

If your cooperative plans to offer the 125 Plan or health reimbursement arrangement (HRA) administered by Cooperative Benefit Administrators, Inc. (CBA) in 2025, here are two key steps you need to take:

  1. If you are adding a new plan or making changes, complete the appropriate plan-related documents and return them to Cooperative Benefit Administrators, Inc. (CBA) at cba.fsa.hra@nreca.coop by Monday, September 30.
  2. Distribute restated summary plan descriptions (SPDs) to your employees and retirees by July 30, 2025, or within 210 days from the restated SPD effective date.

Preparing for 2025
The sample plan documents, forms and guides your co-op will need for the 2025 plan year are now available on the Employee Benefits website:

Refer to these fliers—Making Changes to Your 125 Plan or Making Changes to Your HRA Plan—for details on what’s required for plan adoptions and other plan changes.

Note: If your co-op sponsors a 125 Plan, you must submit a payroll calendar each year for each subgroup administered—regardless of whether you are making changes to your plan. Plan dates in the payroll calendar must all occur within the 2025 calendar year. Submit pay dates to cba.fsa.hra@nreca.coop.

New contribution maximum and carryover amounts
The new participant contribution maximum is $3,200 for health flexible spending accounts (health FSAs) and limited-use (LU) health FSAs. The new carryover amount, if your plan has the carryover option, is $640. These amounts will automatically be updated in your plan, so there’s no need to submit an adoption agreement.

Annual enrollment
You can enroll your employees in 2025 tax-advantaged plans from November 1–30. Look for more information on the open enrollment process in the coming weeks.

Restated SPDs and Plan Documents
SPDs are being restated this year, as they are every five years. If your co-op has made a change in the last five years, you’ll need to update the SPD, as well as the 125 Plan Document and/or HRA Plan Document to reflect the same provisions within the SPD. Co-ops that have not restated their SPD or plan document in the past 10 years should also restate the documents.

The sample SPDs and instructions can be downloaded at BA Guide > Tax-Advantaged Accounts > 125 Plan or HRA page, and then under Resources > Adopting or Renewing a 125 Plan (or an HRA plan) > Plan Documents and Instructions. Here’s what you’ll need to do:

  1. Download the sample SPDs that apply to your co-op’s plans. The SPDs are effective January 1, 2025.
  2. Review and revise the SPDs to reflect your co-op’s specific plan choices. Use the document titled “Instructions for Plan Document and SPD,” which explains how to include the language that describes your plan’s choices.
  3. Make sure the revised SPDs are reviewed by your co-op’s legal counsel.
  4. Distribute the SPDs to plan participants. ERISA rules give co-ops until July 30, 2025, for distribution; however, the sooner participants receive them, the better.

Note: The 125 Plan sample SPD used to contain separate appendices, but is now one document. When reviewing the sample with legal counsel before use, remember to delete the section(s) that your co-op has not elected to offer. Follow the instructions to tailor the document to your co-op’s specific plan.

For any questions about the 125 Plan or HRA, please contact CBA at 866.673.2299 or email cba.fsa.hra@nreca.coop.

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