I had saved your post from a year ago, and recently revisited it to see if it addressed an issue I can't seem to find a definitive answer to. It does not, but I wondered if your contacts ('NCPE'?) for the issue you did address would have some guidance. The issue is whether or not a 2% S corporation shareholder employee can have an HRA that would allow him/her to treat out-of-pocket medical costs (co-pays, deductibles) in the same manner as health insurance premiums, that is, as wages not subject to FICA but eligible for the self-employed health insurance deduction on the Form 1040. I have seen many articles indicating an HRA for a 2% shareholder employee is not allowed, and others indicating that it is allowed because the HRA itself is a Section 105 self-funded insurance plan. Any help you can provide would be greatly appreciated.