Manufacturer-direct drug pricing STRUCTURED FOR ERISA AND HSA compliance
Manufacturer-direct drug pricing STRUCTURED FOR ERISA AND HSA compliance
Every plan type has a compliant path to lower-cost medications.
Every plan type has a compliant path to lower-cost medications.
The Compliance Question
For most employers, the first question is about compliance, not savings.
When plans consider manufacturer-direct pricing, their first concern is usually not the savings, it is how the program interacts with ACA, ERISA, and HSA rules. That concern is well-founded, because changing how a benefit is funded can affect HSA eligibility and annual-limit requirements if not structured carefully.
The Key Principle
For HDHPs, HSA eligibility depends on when the benefit is available.
Get the timing right and HSA contributions stay protected.
How Andel works with your plan
A compliant approach for each common plan structure.
Plan Type
Plan Type
Structure
Structure
HRA Needed?
HRA Needed?
HSA Impact
HSA Impact
Self-funded PPO
Self-funded PPO
Self-funded PPO
Add medication access as plan benefit
Add medication access as plan benefit
No
No
N/A — no HSA issue
N/A — no HSA issue
Self-funded HDHP
Self-funded HDHP
Self-funded HDHP
Add medication access post-deductible
Add medication access post-deductible
No
No
HSA preserved if post-deductible
HSA preserved if post-deductible
Fully-insured (Blue Cross, HMO, etc.)
Fully-insured (Blue Cross, HMO, etc.)
Fully-insured (Blue Cross, HMO, etc.)
Integrated HRA designed to satisfy minimum-value requirements
Integrated HRA designed to satisfy minimum-value requirements
Yes
Yes
Depends on HDHP / non-HDHP design
Depends on HDHP / non-HDHP design
Any plan — taxable payroll approach
Any plan — taxable payroll approach
Any plan — taxable payroll approach
Taxable compensation, not tied to specific medication purchases
Taxable compensation, not tied to specific medication purchases
No
No
HSA eligibility preserved if compensation is not earmarked
HSA eligibility preserved if compensation is not earmarked

Reviewed by ERISA counsel
Built on well-established rules.
Each pathway has been reviewed by ERISA and benefits counsel and is designed around established ACA, ERISA, HSA, and HRA principles. The goal is practical: help plans access meaningful medication savings without relying on aggressive or novel compliance theories.
Compliance, simplified
Affordable access without compromising compliance.
Affordable access without compromising compliance.
The compliant paths are well established. Andel helps you find the one that fits your plan.
The compliant paths are well established. Andel helps you find the one that fits your plan.
ACA, ERISA & HSA aligned
Established compliant paths
Built around your plan