Premium Expense Auto Reimbursement Policy

Purpose and Authority: This Premium Expense Auto Reimbursement Policy (the “Policy”) implements the ICHRA Plan (the “Plan”)’s auto reimbursement procedure under Section 4.8(a) of the Plan. This Policy establishes reasonable procedures intended to satisfy the ongoing substantiation requirement in 26 CFR 54.9802-4(c)(5)(ii). Capitalized terms have the meanings in the Plan.

Scope: This Policy applies to automatic reimbursement of Premium Expenses for Participants who elect automatic reimbursement and meet the ongoing substantiation requirements described below.

Substantiation for Auto Reimbursement: A Participant satisfies the ongoing substantiation requirement for auto reimbursement of Premium Expenses by:

(1) Requesting auto reimbursement under the Plan;

(2) Providing annual proof of Integrated Coverage for the Participant and any Covered Dependents, either by submitting third-party documentation (such as an insurance card, explanation of benefits, premium bill, or Exchange documentation) or other evidence acceptable to the Administrator; and

(3) Certifying, as part of the auto reimbursement request or otherwise, that the Participant and any Covered Dependents are enrolled in Integrated Coverage, that the Participant intends to maintain such coverage through the remainder of the current Plan Year, and that the Participant will notify the Employer/Administrator immediately if coverage is cancelled, terminated, or otherwise not maintained for any reason during the Plan Year.

Reliance; Actual Knowledge: The Plan may rely on a Participant’s attestation or documentation unless the Plan, the Employer has actual knowledge that any individual for whom reimbursement is requested was not, or will not be, enrolled in Integrated Coverage for the applicable period. Upon actual knowledge, the Plan will suspend automatic reimbursements for the affected period(s) and may seek recovery of any overpayments.

Method; Frequency; Documentation: Auto reimbursement may be administered through electronic means, including electronic attestations, provided the process is reasonably designed to verify enrollment and the frequency of the auto reimbursement may be established by the Employer. Participants must retain and furnish, upon request, documentation supporting their attestations and reimbursement claims.